- 7 -
in a vacuum isolated from the actual facts that affect value.
Estate of Andrews v. Commissioner, 79 T.C. 938, 956 (1982).
The determination of fair market value is a question of
fact. Hamm v. Commissioner, 325 F.2d 934, 938 (8th Cir. 1963),
affg. T.C. Memo. 1961-347; Estate of Newhouse v. Commissioner,
supra at 217. In general, property is valued as of the valuation
date on the basis of market conditions and facts available on
that date--without regard to hindsight. Subsequent events are
considered only to the extent that they were reasonably
foreseeable at the date of valuation. Estate of Gilford v.
Commissioner, 88 T.C. 38, 52 (1987). Moreover, valuation is
generally based on the highest and best use of the property to be
valued. Buse v. Commissioner, supra at 1137.
Both parties have submitted very extensive expert witness
reports and testimony relating to the fair market value of the
Washington properties. While expert opinions can assist the
Court in evaluating a claim, we are not bound by the opinion of
any expert witness and may reach a decision based on our own
analysis of all the evidence in the record. Helvering v.
National Grocery Co., 304 U.S. 282, 295 (1938); Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285; Estate of Newhouse v. Commissioner, supra at 217.
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