Jane Crocker, F.K.A. Jane C. Jacobs, et al. - Page 103

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          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.                   



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