Eugene D. Lanier, Inc. - Page 14

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          further assert that the Corporation has already recognized as               
          income the $1,532 difference between the Property's claimed FMV             
          of $425,000 and the Corporation's adjusted basis therein, and               
          that no additional income must be recognized by the Corporation             
          under section 311(b)(1).                                                    
               The parties primarily rely upon their experts' testimony and           
          reports to support their respective positions regarding the FMV             
          of the Property.  Expert opinion sometimes aids the Court in                
          determining valuation; other times, it does not.  See Laureys v.            
          Commissioner, 92 T.C. 101, 129 (1989).  We evaluate such opinions           
          in light of the demonstrated qualifications of the expert and all           
          other evidence of value in the record.  Estate of Newhouse v.               
          Commissioner, 94 T.C. 193, 217 (1990); Parker v. Commissioner, 86           
          T.C. 547, 561 (1986); Johnson v. Commissioner, 85 T.C. 469, 477             
          (1985).  We are not bound, however, by the opinion of any expert            
          witness when that opinion contravenes our judgment.  Estate of              
          Newhouse v. Commissioner, supra at 217; Parker v. Commissioner,             
          supra at 561.  Although we may accept the opinion of an expert in           
          its entirety, Buffalo Tool & Die Manufacturing Co. v.                       
          Commissioner, 74 T.C. 441, 452 (1980), we also may be selective             
          in the use of any portion thereof, Parker v. Commissioner, supra            
          at 562.  Consequently, we take into account expert opinion                  
          testimony only to the extent that it aids us in arriving at the             
          FMV of the property.                                                        

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