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T.C. 872, 881 (1983), affd. 757 F.2d 1208 (11th Cir. 1985). The
fair market value of an item of property shall not
be determined by the sale price of the item in a market
other than that in which such item is most commonly
sold to the public, taking into account the location of
the item wherever appropriate. Thus, in the case of an
item of property * * * which is generally obtained by
the public in the retail market, the fair market value
of such an item of property is the price at which the
item or a comparable item would be sold at retail.
* * * The value is generally to be determined by
ascertaining as a basis the fair market value as of the
applicable valuation date of each unit of property.
* * * [Sec. 20.2031-1(b), Estate Tax Regs.]
2. The Experts
Each party submitted an expert report, supported by
extensive testimony, that selected a different market in which to
value the collection. The experts’ contradictory assumptions and
their differing conclusions about which market is relevant and
the state of those different markets in 1985 partly explain the
extent of their disagreement.
Expert opinions can aid the Court in understanding an area
of specialized training, knowledge, or judgment, Perdue v.
Commissioner, T.C. Memo. 1991-478, even when the opinions are
poles apart as they are in this case. While 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
are not bound by the expert opinions proffered on behalf of
either party, Silverman v. Commissioner, 538 F.2d at 933, and may
selectively use any portion of such reports and testimony, IT&S
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