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B. Fair Market Value of the Gifts From Petitioner to His
Children
1. Expert Testimony
Petitioner called an expert witness to give his opinion
about the value of the gifts of Crossroads' stock petitioner made
to his children in 1992 and 1993. We may accept or reject expert
testimony according to our own judgment, and we may be selective
in deciding what parts of an expert's opinion, if any, we will
accept. Estate of Newhouse v. Commissioner, 94 T.C. 193, 217
(1990); Parker v. Commissioner, 86 T.C. 547, 562 (1986).
Respondent did not call an expert to testify. Raymond T.
Wise, Jr. (Wise), is an Internal Revenue Service (IRS) estate and
gift tax attorney who appraised Crossroads' common stock in this
case. His appraisal is the basis for respondent's trial
position.
The opinions of petitioner's and respondent's appraisers and
the positions of the parties are as follows:
Petition/
Petitioner's petitioner's Deficiency notice and
returns expert Gallagher answer/Wise
Jan. 1, $303 per 0 per share $704 per share
1992, gift share
Jan. 1, 303 per $215 per share 1,010 per share
1993, gift share
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