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defeat for one or the other, rather than a middle-of-
the-road compromise which we suspect each of the
parties expects the Court to reach. * * *
The record in this case would not allow the Court to accept one
or the other of the parties' valuations outright because each was
so grossly contrary to the evidence. Buffalo Tool & Die
Manufacturing Co. v. Commissioner, supra; see also Estate of
Halas v. Commissioner, 94 T.C. 570, 577-578 (1990).
We note that if petitioners had not met the burden of
producing sufficient evidence to support an independent valuation
over respondent’s valuation, we would have had to hold for
respondent even if we had rejected the valuation of respondent’s
expert. In Anselmo v. Commissioner, 80 T.C. at 884-885, we
rejected the valuations of both parties' experts, but upheld the
Commissioner’s determination of value used in the notice of
deficiency. In Anselmo, the testimony of the taxpayer’s experts
showed there was no reliable way of working back from the figures
they computed because they had relied upon the retail store
market and not the wholesale market. In that case, we held that
the wholesale market was the relevant market for low-quality,
unset gemstones. The ultimate consumers of those unset gemstones
were jewelers who would in turn mount them into settings to sell
to retail customers, who were the ultimate consumers of low-
quality, set gemstones. Id.
We need not rely upon the burden of proof to value most of
petitioner's collection. Everett, petitioners' expert, used the
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