- 59 -
Petitioners argue that there is no basis upon which the
values they determined for the Securities may be disregarded
because the conclusions reached by Goldman Sachs have substantial
support, and respondent presented no probative evidence to the
contrary. Nonetheless, we are not required to adopt the values
advanced by Goldman Sachs. Cupler v. Commissioner, 64 T.C. 946,
955-956 (1975). Valuation issues are questions of fact and the
trier of fact must consider all relevant evidence to draw the
appropriate inferences. Commissioner v. Scottish Am. Inv. Co.,
323 U.S. 119, 123-125 (1944); Skripak v. Commissioner, 84 T.C.
285, 320 (1985); Cupler v. Commissioner, supra at 955. We weigh
expert testimony in light of the expert's qualifications as well
as all the other credible evidence in the record. Seagate Tech.,
Inc. & Consol. Subs. v. Commissioner, supra. We are not bound by
the opinion of any expert witness, and we shall accept or reject
that expert testimony when, in our best judgment, based on the
record, it is appropriate to do so. Id., and the cases cited
therein. While we may choose to accept in its entirety the
opinion of one expert, we may also be selective in the use of any
portion of that opinion. Id.
We, however, do not reject expert evidence without objective
reasons for doing so. Neely v. Commissioner, 85 T.C. 934, 946
(1985). Respondent contends that the Goldman Sachs Valuation
contains errors, omissions, and is based on estimates and
assumptions not supported by independent evidence or
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