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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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