- 93 - as well as the testimony presented at trial, we conclude that petitioners have successfully established that respondent's determination with respect to the fair market value of the Redwood City Fox is deserving of adjustment. We again note that valuation is not a precise science, and determining the fair market value of donated property on a given date is a question of fact to be resolved on the basis of the entire record. See McShain v. Commissioner, 71 T.C. 998, 1004 (1979); Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). Expert opinion evidence is obviously admissible and relevant on the question of value and is intended to help the Court understand areas requiring specialized training, knowledge, or judgment. However, 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 expert opinions in light of the demonstrated qualifications of the expert and all other evidence of value in the record. Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir. 1973), affg. 54 T.C. 493 (1970); Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990); Parker v. Commissioner, 86 T.C. 547, 561 (1986). As the trier of fact, we are not bound by the opinion proffered by any expert witness when that opinion contravenes our judgment. Helvering v. National Grocery Co., 304 U.S. 282, 295 (1938); Estate of Newhouse v. Commissioner, supra at 217; Parker v. Commissioner, supra at 561. While we may accept the opinion of an expert in its entirety, Buffalo Tool & Die Mfg. Co. v.Page: Previous 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Next
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