- 7 -
the value of that stock interest was $1,110,000. The estate also
modified on brief its prior positions as to the value on the
valuation date of the stock interest in question. The estate now
claims that that value was $604,777.
As is customary in valuation cases, the parties rely exten-
sively on the opinions of their respective experts to support
their differing views about the fair market value on the valua-
tion date of decedent's 50-percent stock interest in B&W
Longview. The estate relies on Richard P. Bernstein (Mr.
Bernstein), a member of the American Society of Appraisers, who
is the founder and president of the business valuation firm of
Bernstein, Phalon & Conklin. Respondent relies on Monty L.
Harrell (Mr. Harrell), who is employed by the Internal Revenue
Service as an economist. Although Mr. Harrell is not a member of
the American Society of Appraisers, he has taken business valua-
tion courses offered by that organization.
We evaluate the opinions of experts in light of the demon-
strated qualifications of each expert and all other evidence in
the record. Anderson v. Commissioner, 250 F.2d 242, 249 (5th
Cir. 1957), affg. in part and remanding in part T.C. Memo. 1956-
178; Parker v. Commissioner, 86 T.C. 547, 561 (1986). We have
broad discretion to evaluate "'the overall cogency of each
expert's analysis.'" Sammons v. Commissioner, 838 F.2d 330, 334
(9th Cir. 1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909
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