Estate of Eldon L. Auker, Deceased, Kimberlee J. Auker, Independent Personal Representative - Page 39

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        absorption discount applied to undeveloped lots totaling 302 acres).          
        The law of supply and demand supports our application of the concept          
        of blockage to these assets in that a sale of an exceptionally large          
        block of one type of property may generate less proceeds than if the          
        seller were to sell each piece of that block separately at the market         
        price.  The market may only handle so many pieces of one type of              
        property in a limited time, and, when the tendered number of a single         
        type of property is greater than the number that the market can               
        absorb, the market is unable to handle the exceptionally large block          
        at that time.  Thus, a seller desiring to sell such a large block at          
        that time may be forced to sell the block at a price per piece that           
        is less than the quoted price for each piece.                                 
             Respondent and the estate both rely on the testimony of experts          
        to support their respective positions on the presence in this case of         
        the market absorption discount.  We have wide discretion when it              
        comes to accepting the testimony of an expert.  Sometimes, he or she          
        will help us decide a case.  See, e.g., Booth v. Commissioner,                
        108 T.C. 524, 573 (1997); Trans City Life Ins., Co. v. Commissioner,          
        106 T.C. 274, 302 (1996); see also M.I.C. Ltd. v. Commissioner,               
        T.C. Memo. 1997-96.  Other times, he or she will not.  See, e.g.,             
        Estate of Scanlan v. Commissioner, T.C. Memo. 1996-331; Mandelbaum v.         
        Commissioner, T.C. Memo. 1995-255, affd. without published opinion            
        91 F.3d 124 (3d Cir. 1996).  We weigh an expert's testimony in light          







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