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is based upon all relevant facts. Sec. 20.2031-1(b),
Estate Tax Regs.
In determining the value of an asset, we are not
bound by the formulae and opinions proffered by an expert,
especially when they are contrary to our judgment. Chiu
v. Commissioner, 84 T.C. 722, 734 (1985). Instead, we may
reach a decision as to the value of the property based on
our own analysis of all the evidence in the record,
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir.
1976), affg. T.C. Memo. 1974-285; Hamm v. Commissioner,
supra at 941, using all of one party's expert opinion,
Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74
T.C. 441, 452 (1980), or selectively employing any portion
of such an opinion, see Parker v. Commissioner, 86 T.C.
547, 562 (1986).
With the above principles in mind, we have reviewed
the arguments of the parties, together with the testimonial
and documentary evidence presented. Based upon all of the
facts and circumstances of this case, we believe that the
decedent's land was worth $600,000 on the date of the
decedent's death, September 7, 1990. We set forth below
several comments about the arguments of the parties and the
facts of this case.
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