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decedent transferred to petitioner in 1980 and 1983. 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. Parker v. Commissioner, 86 T.C.
547, 562 (1986).
There were five expert witnesses at the trial. Three were
appraisers: David R. Elmore, Jr. (Elmore), for respondent, and
Dr. C. Donald Wiggins (Wiggins) and Philip J. Moses (Moses) for
petitioner. The opinions of petitioners' and respondent's
appraisers and the positions of the parties5 are as follows:
Deficiency
Ps' Returns/ Ps' Experts Notices and R's Expert
Petition Moses/Wiggins1 Answers Elmore
Putnam $263,040 $211,000 $759,050 $799,000
Co. ($111.46/ ($89.41/acre) ($321.63/ ($350/acre)
property acre) acre)
Clay Co. 276,000 221,000 989,662 1,041,750
property ($119.22/ ($95.46/acre) ($427.50/ ($450/acre)
acre) acre)
Property 122,400 143,000 360,500 379,467
in estate ($145.15/ ($169.58/ ($427.50/ ($450/acre)
acre) acre) acre)
1 Moses valued a fee simple interest in the three parcels of
property. Wiggins applied discounts for fractional interests in
real estate to Moses' values for the three parcels of real
property.
Petitioners' other experts were Frank Scruby, a Florida real
estate attorney, and Donald Pitts, a Florida banker.
5 Respondent determined in the gift tax notice of deficiency
that the 1980 gift consisted of 2,283 acres instead of 2,360
acres. This reduced the amount of the 1980 taxable gift.
However, respondent does not now seek an increased deficiency
based on 2,360 acres.
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