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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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