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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...)
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