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We decline to address in any significant detail any of the
further attempts by either party to discredit the appraisal
reports presented by the party’s opponent. We recognize and
accept that Tidwell, Hearn, Young, and Dilmore are each experts
in their profession of real estate appraising, but we further
recognize that reasonable experts specializing in the same
profession often disagree. It is to such disagreement that we
attribute any differences in substance, style, and quality among
the appraisal reports presented by each party.
2. Property Valuation
Property includable in a decedent's gross estate is
generally reported at its fair market value on the date of the
decedent's death. Sec. 2031(a);1 sec. 20.2031-1(b), Estate Tax
Regs. Fair market value is the "price at which the property
would change hands between a willing buyer and a willing seller,
neither being under any compulsion to buy or to sell and both
having reasonable knowledge of relevant facts." United States v.
Cartwright, 411 U.S. 546, 551 (1973); Estate of Bright v. United
States, 658 F.2d 999, 1005-1006 (5th Cir. 1981); Frazee v.
Commissioner, supra at 562; sec. 20.2031-1(b), Estate Tax Regs.
The determination of value is to be made as of the valuation
date, and knowledge of unforeseeable future events that may have
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the date of the decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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