- 11 -
that the properties are actually comparable. In her report,
dated January 1998, Horn states that she could find no comparable
properties listed for rent at the time she did her analysis.
Furthermore, her search of newspaper archives produced only one
comparable property located in the same neighborhood as
petitioner's property; this property was offered for rent in
December 1991 at $925 per month.
Finally, Horn's appraisal of the work performed by Murray
was a recitation of representations made to her by petitioner.
Thus, Horn made no independent appraisal of the value of Murray's
work. Expert testimony is not useful when the expert is merely
an advocate for the position argued by one of the parties.
Laureys v. Commissioner, 92 T.C. 101, 129 (1989).
Where necessary, we may reach a determination of value based
upon our own examination of the evidence in the record. Lukens
v. Commissioner, 945 F.2d 92, 96 (5th Cir. 1991) (citing
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
affg. T.C. Memo. 1974-285), affg. Ames v. Commissioner, T.C.
Memo. 1990-87. Moreover, because valuation is necessarily an
approximation, it is not required that the value we determine be
one as to which there is specific testimony, provided it is
within the range of figures that properly may be deduced from the
evidence. Silverman v. Commissioner, supra; Anderson v.
Commissioner, 250 F.2d 242, 249 (5th Cir. 1957), affg. in part
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