Estate of Artemus D. Davis, Deceased, Robert D. Davis, Personal Representative - Page 12

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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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