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judgment. See Fed. R. Evid. 702; Snyder v. Commissioner, 93 T.C.
529, 534 (1989). The Court, however, is not bound by an expert's
opinion. We weigh an expert's testimony in light of his or her
qualifications and with respect to all credible evidence in the
record. Depending on what we believe is appropriate under the
facts and circumstances of the case, we may either reject an
expert's opinion in its entirety, accept it in its entirety, or
accept selective portions of it. See Helvering v. National
Grocery Co., 304 U.S. 282, 294-295 (1938); Seagate Tech., Inc. &
Consol. Subs. v. Commissioner, 102 T.C. 149, 186 (1994).
Moreover, where experts offer divergent estimates of fair market
value, we decide what weight to give these estimates by examining
the factors they used in arriving at their conclusions. See
Casey v. Commissioner, 38 T.C. 357, 381 (1962). We have broad
discretion in selecting valuation methods, see Estate of
O'Connell v. Commissioner, 640 F.2d 249, 251 (9th Cir. 1981),
affg. on this issue and revg. in part T.C. Memo. 1978-191, and
the weight to be given the facts in reaching our conclusion
because "finding market value is, after all, something for
judgment, experience, and reason", see Colonial Fabrics, Inc. v.
Commissioner, 202 F.2d 105, 107 (2d Cir. 1953), affg. a
Memorandum Opinion of the Court.
Where necessary, we may reach a determination of value based
upon our own examination of the evidence in the record. See
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