Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix - Page 21

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          condition has the potential of inflicting a severe financial                
          burden on plans to develop the parcel.                                      
               The Schoel report also briefly addresses the shape of parcel           
          A and its zoning classification.  With regard to its shape, the             
          report describes parcel A as essentially two distinct parcels               
          because of the location of the Bell property.  As to the zoning             
          of parcel A, the Schoel report generally concludes that a change            
          in the zoning classification of that portion of parcel A without            
          the corporate limits of the city of Birmingham from residential             
          to commercial would be difficult.                                           
                                       OPINION                                        
               Both parties introduced appraisal reports compiled by                  
          qualified appraisers, each of whom was familiar with property               
          values in the vicinity of Birmingham, Alabama.  Such expert                 
          opinion evidence is admissible if it will assist the trier of               
          fact to understand evidence that will determine the fact in                 
          issue.  See Fed. R. Evid. 702.  We must weigh expert opinion                
          evidence in light of the demonstrated qualifications of the                 
          expert and all other credible evidence.  Johnson v. Commissioner,           
          85 T.C. 469, 477 (1985).  However, we are not bound by the                  
          opinion of any expert witness when that opinion is contrary to              
          our judgment.  Estate of Newhouse v. Commissioner, 94 T.C. 193,             
          217 (1990).  While we may choose to accept the opinion of one               
          expert in its entirety, Buffalo Tool & Die Manufacturing Co. v.             
          Commissioner, 74 T.C. 441, 452 (1980), we may also be selective             




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