-15- 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 sharePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011