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The fair market value of donated property as of a given date
is a question of fact to be determined from the entire record.
Symington v. Commissioner, 87 T.C. 892, 896 (1986); Zmuda v.
Commissioner, 79 T.C. 714, 726 (1982), affd. 731 F.2d 1417 (9th
Cir. 1984). Fair market value reflects the highest and best use
of the property on the date of valuation. Stanley Works & Subs.
v. Commissioner, 87 T.C. 389, 400 (1986). The highest and best
use of property is the realistic, objective potential use to
which the property can be put. Id.; see also Olson v. United
States, 292 U.S. 246, 255-256 (1934). The determination of fair
market value is not dependent upon whether the property is
actually being put to its highest and best use. Symington v.
Commissioner, supra at 897. Thus, in determining the reasonable
and probable use that supports the highest present value, we
focus on the "highest and most profitable use for which the
property is adaptable and needed or likely to be needed in the
reasonably near future". Olson v. United States, supra at 255.
In this case, the parties have relied extensively on the
testimony of expert witnesses to support their respective views
on the fair market value. Before turning to an analysis of the
divergent expert opinions, we note that, as the trier of fact,
the Court must weigh the evidence presented by the experts in
light of their demonstrated qualifications in addition to all
other credible evidence. Estate of Christ v. Commissioner, 480
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