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Based on the foregoing, we agree with petitioner that the
Interstate Valuation does not constitute an admission by
petitioners.
Even had we agreed with respondent that the Interstate
Valuation constituted an admission, we would not be precluded
from reaching a different value from that reached by Interstate.
See Mauldin v. Commissioner, 60 T.C. at 760-761 (although
appraisal report was admitted as an admission against
Government's interest, the Court reached its own opinion as to
value of donated property based on the record as a whole); see
also Transamerica Corp. v. United States, 15 Cl. Ct. at 471-472
(same). Respondent provided neither the qualifications of the
preparer of the Interstate Valuation nor the bases of the
opinions expressed therein. No one involved in preparing the
Interstate Valuation was made available for cross-examination.
Accordingly, we would accord the Interstate Valuation little, if
any, weight if we were to admit it. See Pack v. Commissioner,
T.C. Memo. 1980-65 n.23; see also Harris v. Commissioner, 46 T.C.
672, 674 (1966); Rowland v. Commissioner, 5 B.T.A. 770, 771-772
(1926); Montgomery Bros. & Co. v. Commissioner, 5 B.T.A. 258, 260
(1926); Kilburn Lincoln Mach. Co. v. Commissioner, 2 B.T.A. 363,
364 (1925).
Respondent further contends that the Interstate Valuation is
admissible under the business records exception to the hearsay
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