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discount applied for lack of marketability. See Estate of
Trenchard v. Commissioner, supra.
B. Expert Reports Regarding the Fair Market Value
of the Deft Stock
In deciding valuation cases, courts often look to expert
opinions. The Court is not bound by the opinion of any expert,
and we may accept or reject in full or in part experts' opinions
proffered by the parties. 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); Estate of
Newhouse v. Commissioner, supra at 217; Parker v. Commissioner,
86 T.C. 547, 562 (1986); Chiu v. Commissioner, 84 T.C. 722, 734
(1985). Moreover, the Court is free to value property at a
figure for which there is no specific testimony as long as it is
within the range of figures that can be adduced from the
evidence. See Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976), affg. T.C. Memo. 1974-285; Estate of Davis v.
Commissioner, 110 T.C. 530, 537 (1998).
The parties herein rely on experts' opinions to establish
the fair market value of decedent's interest in Deft and whether
and in what amount any discount or premium should be applied to
that interest. Petitioner bears the burden of proof on these
issues. See Rule 142(a).
1. Petitioner's Expert
Petitioner relies on a report compiled by Higgins, Marcus &
Lovett, Inc. (HML), to establish that the fair market value of
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