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ground that such material may provide information relevant to our
determination of whether there was inurement.
The parties primarily rely upon their experts' testimony and
reports to support their respective positions regarding the fair
market value of the hospital. Expert opinion sometimes aids the
Court in determining valuation; other times, it does not. See
Laureys v. Commissioner, 92 T.C. 101, 129 (1989). We evaluate
such opinions in light of the demonstrated qualifications of the
expert and all other evidence of value in the record. Estate of
Newhouse v. Commissioner, 94 T.C. at 217. We are not bound,
however, by the opinion of any expert witness when that opinion
contravenes our judgment. Id. We may accept the opinion of an
expert in its entirety, Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980), or we may be selective in
the use of any portion thereof, Parker v. Commissioner, 86 T.C.
547, 562 (1986).
Initially, we deal with petitioner's objection to the
admission of the report of respondent's expert, Mr. Shelton, on
the ground that he assumed the role of an advocate. See Laureys
v. Commissioner, supra. Petitioner points to Mr. Shelton's use
of terms such as "collusion", "in secrecy", "the closed and
secret sale", and "inside knowledge", when describing the
appraisal of Mr. Sheldrick and AMH's purchase of the hospital.
That appraisal was utilized by Messrs. O'Donnell and Rosenkranz
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