- 25 - Commissioner, 92 T.C. 312, 335 (1989). The fair market value of a promissory note is a question of fact which depends on factors known or reasonably expected to exist on the valuation date. Riss v. Commissioner, 478 F.2d 1160 (8th Cir. 1973), affg. in part 56 T.C. 388 (1971); Estate of Johnson v. Commissioner, 77 T.C. 120, 124 (1982), revd. on other grounds 718 F.2d 1303 (5th Cir. 1983). 2. Expert Opinions Both parties relied on the opinions of experts. Expert witnesses' opinions may help the Court understand an area requiring specialized training, knowledge, or judgment. Snyder v. Commissioner, 93 T.C. 529, 534 (1989). We may be selective in deciding what part of an expert's opinion we will accept. Helvering v. National Grocery Co., 304 U.S. 282, 295 (1938). Petitioners relied on the expert testimony of Dr. Charles Brandon (Brandon). Brandon testified that the rate of discount for a note related to an adult entertainment business was substantial. Brandon based his estimate of fair market value in part on Waldorf's sale to Darlene Wiltzius.5 Brandon assumed 5Respondent does not contend that we may not consider an actual sale of the asset at issue after the valuation date. Estate of Kaplin v. Commissioner, 748 F.2d 1109, 1111 (6th Cir. 1984), revg. T.C. Memo. 1982-440; Estate of Spruill v. (continued...)Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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