- 8 -
(1989). We evaluate such opinions in light of the demonstrated
qualifications of the expert and all other evidence of value.
Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990);
Parker v. Commissioner, 86 T.C. 547, 561 (1986); Johnson v.
Commissioner, 85 T.C. 469, 477 (1985). We are not bound,
however, by the opinion of any expert witness when that opinion
is contrary to our judgment. Estate of Newhouse v. Commissioner,
supra at 217; Parker v. Commissioner, supra at 561. Although we
may accept the opinion of an expert in its entirety, Buffalo Tool
& Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980),
we also may be selective in the use of any portion of such an
opinion, Parker v. Commissioner, supra at 562. Consequently, we
will take into account expert opinion testimony to the extent
that it aids us in arriving at the fair market value of the
property.
The value of decedent's gross estate is the fair market
value of property includable in the gross estate. Sec. 2031.
Fair market value is defined as "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 Newhouse v.
Commissioner, supra at 217; sec. 20.2031-1(b), Estate Tax Regs.
Because valuation is necessarily an approximation, the figure at
which the Court arrives need not be one as to which there is
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