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In addition to the subdivision plans, Mr. Flint prepared a
detailed report analyzing the development potential of the
Property. Mr. Flint's report includes an extensive soil analysis
of the Property, as well as a summary of discussions with
Framingham town officials and consultants regarding the
development of the Property's sewer system. Mr. Flint's revised
subdivision plan shows that the Property could be subdivided into
107 house lots.8
Before turning to an analysis of the divergent expert
opinions, we note that, as the trier of fact, the Court must
weigh the evidence presented by the experts in light of their
demonstrated qualifications in addition to all other credible
evidence. Estate of Christ v. Commissioner, 480 F.2d 171, 174
(9th Cir. 1973), affg. 54 T.C. 493 (1970). However, we are not
bound by the opinion of any expert witness when that opinion is
contrary to our judgment. Estate of Kreis v. Commissioner, 227
F.2d 753, 755 (6th Cir. 1955), affg. T.C. Memo. 1954-139; Chiu v.
Commissioner, 84 T.C. 722, 734 (1985). Rather, we may accept or
reject expert testimony as we find appropriate in our best
judgment. Helvering v. National Grocery Co., 304 U.S. 282, 294-
295 (1938); Seagate Tech., Inc. & Consol. Subs. v. Commissioner,
102 T.C. 149, 186 (1994). Moreover, even if we accept the
general methodology of an expert witness, we may reject that
8Mr. Flint's original subdivision plan contained only 96
house lots.
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