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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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