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Barker Elliott, Inc., and (2) Shannon Pratt (Mr. Pratt), who is an
accredited senior appraiser and fellow of the American Society of
Appraisers and a founder and managing director of the business
valuation firm of Willamette Management Associates. Respondent
relies on John A. Thomson (Mr. Thomson), who is an accredited
senior appraiser of the American Society of Appraisers and a vice
president and the managing director of the Long Beach, California,
office of the business valuation firm of Klaris, Thomson &
Schroeder, Inc. Each of the experts prepared an initial expert
report (expert report)4 and a rebuttal expert report (rebuttal
report).5
We evaluate the opinions of experts in light of the
demonstrated qualifications of each expert and all other evidence
in the record. Anderson v. Commissioner, supra at 249; Parker v.
Commissioner, 86 T.C. 547, 561 (1986). We have broad discretion
to evaluate "'the overall cogency of each expert's analysis.'"
Sammons v. Commissioner, 838 F.2d 330, 334 (9th Cir. 1988)(quoting
Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir. 1986), affg. in
part and revg. in part T.C. Memo. 1983-200), affg. in part and
4 The expert report of petitioner's expert Mr. Howard is
identical to Mr. Howard's appraisal on which the value reported
in the gift tax return for each of the two gifts in question was
based. Hereinafter, we shall refer to Mr. Howard's appraisal as
his expert report.
5 Each of petitioner's experts prepared a rebuttal report with
respect to the expert report of respondent's expert, and
respondent's expert prepared separate rebuttal reports with
respect to the expert reports of petitioner's two experts.
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