- 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.
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