Charles C. Dockery, Donor - Page 15

                                        -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      share                                                       










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