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peculiar characteristics of these hypothetical persons are not
necessarily the same as the individual characteristics of an
actual seller or an actual buyer. See Estate of Bright v. United
States, 658 F.2d 999, 1005-1006 (5th Cir. 1981). The
hypothetical willing buyer and willing seller are presumed to be
dedicated to achieving the maximum economic advantage. See
Estate of Newhouse v. Commissioner, supra at 218. This advantage
must be achieved in the context of market and economic conditions
on the valuation date. See id. The hypothetical sale should not
be constructed in a vacuum isolated from actual facts that affect
value. See Estate of Andrews v. Commissioner, supra at 956.
As is customary in valuation cases, the parties rely
primarily on expert opinion evidence to support their contrary
valuation positions. Opinion testimony of an expert is
admissible if and because it will assist the trier of fact to
understand evidence that will determine a fact in issue. See
Fed. R. Evid. 702. We evaluate the opinions of experts in light
of the demonstrated qualifications of each expert and all other
evidence in the record. See Parker v. Commissioner, 86 T.C. 547,
561 (1986). We are not bound by the opinion of an expert
witness, especially when such opinion is contrary to our
conclusions. See IT&S of Iowa, Inc. v. Commissioner, 97 T.C.
496, 508 (1991). If experts offer divergent estimates of fair
market value, we decide what weight to give these estimates by
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