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disclosed facts on which it is based. See Tripp v. Commissioner,
337 F.2d 432, 434 (7th Cir. 1964), affg. T.C. Memo. 1963-244. We
are not bound by the formulas and opinions proffered by an
expert, especially when they are contrary to our judgment. Orth
v. Commissioner, supra; Estate of Kreis v. Commissioner, 227 F.2d
753, 755 (6th Cir. 1955), affg. T.C. Memo. 1954-139. Instead, we
may reach a decision of value based on our own analysis of all
the evidence in the record. Silverman v. Commissioner, supra;
Hamm v. Commissioner, supra at 940-941. While 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
may be selective in the use of any portion of such an opinion,
Parker v. Commissioner, supra at 562. We may reject the opinion
of an expert in its entirety. Orth v. Commissioner, supra;
Parker v. Commissioner, supra at 562-565. A sound valuation is
based upon all relevant facts, and we may reach a decision as to
the value of the property based on our own analysis of all the
evidence in the record. Silverman v. Commissioner, supra at 933;
Hamm v. Commissioner, supra at 941.
Even if only one party proffers the opinion of an expert,
such as is the case here, we are not required to accord that
opinion total or even partial acceptance. Tripp v. Commissioner,
supra; Estate of Gilford v. Commissioner, 88 T.C. 38, 56 (1987).
Where there is a significant error in that opinion, appropriate
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