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'value a specific property has for a specific use' and
this value is not necessarily synonymous with market
value.
We have wide discretion when it comes to accepting expert
testimony. Sometimes, an expert will help us decide a case.
See, e.g., Booth v. Commissioner, 108 T.C. 524, 573 (1997); Trans
City Life Ins. Co. v. Commissioner, 106 T.C. 274, 302 (1996); see
also M.I.C. Ltd. v. Commissioner, T.C. Memo. 1997-96; Estate of
Proios v. Commissioner, T.C. Memo. 1994-442. Other times, he or
she will not. See, e.g., Estate of Scanlan v. Commissioner,
supra; Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd.
without published opinion 91 F.3d 124 (3d Cir. 1996). We weigh
an expert's testimony in light of his or her qualifications and
with proper regard to all other credible evidence in the record.
See Estate of Kaufman v. Commissioner, T.C. Memo. 1999-119. We
may accept or reject an expert's opinion in toto, or we may pick
and choose the portions of the opinion which we choose to adopt.
See Helvering v. National Grocery Co., 304 U.S. at 294-295;
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
affg. T.C. Memo. 1974-285; Parker v. Commissioner, 86 T.C. 547,
562 (1986); Estate of Kaufman v. Commissioner, supra; see also
Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506. The mere
fact that the position of one party may be unsupported by expert
testimony does not necessarily mean that the other party's
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