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F.2d 1174 (9th Cir. 1986); Estate of Williams v. Commissioner,
T.C. Memo. 1998-59; Mooneyham v. Commissioner, T.C. Memo. 1991-
178; Estate of Sels v. Commissioner, T.C. Memo. 1986-501.
Fractional interest discounts may be necessary to compensate a
willing buyer for the lack of control, lack of marketability,
illiquidity, and potential partitioning expenses associated with
such interests. See Estate of Pillsbury v. Commissioner, T.C.
Memo. 1992-425.
Petitioner primarily relies on an appraisal report prepared
by Paul E. Talmage (Mr. Talmage) to establish the appropriate
blockage and fractional interest discounts. Respondent relies on
an appraisal report prepared by Karen Simons (Ms. Simons).
We have wide discretion in accepting expert testimony. See
Helvering v. National Grocery Co., 304 U.S. 282, 294-295 (1938).
We examine the expert’s qualifications and compare his or her
testimony with all other credible evidence in the record. We may
accept or reject an expert’s opinion in toto, or we may pick and
choose the portions of the opinion that we wish to adopt. See
id.; Seagate Tech., Inc., & Consol. Subs. v. Commissioner, 102
T.C. 149, 186 (1994); Estate of Newhouse v. Commissioner, 94 T.C.
193, 218 (1990); Parker v. Commissioner, 86 T.C. 547, 562 (1986).
Mr. Talmage was recognized by the Court as an expert in real
estate appraisal, including blockage and fractional interest
discounts. He is a member of the Appraisal Institute and has
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