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C. Court's Analysis and Conclusions
As noted earlier, we are free to accept or reject in full or
in part experts' opinions proffered by the parties. See
Helvering v. National Grocery Co., 304 U.S. at 294-295; Seagate
Tech., Inc., & Consol. Subs. v. Commissioner, 102 T.C. at 186;
Estate of Newhouse v. Commissioner, 94 T.C. at 217. Each of the
experts' reports is susceptible to criticism. We however believe
the fair market value reached in the HML report better represents
the fair market value of decedent's interest. Because of the
limitations imposed by respondent on BVS, we reject the BVS
report and adopt in part, as explained infra, the HML report.
1. Valuation Methods Accepted by Court
The HML report determined the weighted average unadjusted
value based on the three different valuation methods was
$10,196,000. HML's application of the asset method was vague and
generally unhelpful. Furthermore, we believe HML may have
improperly applied that method. We do not rely on this method to
determine the value of decedent's interest.
Respondent does not object to HML's computations of the
unadjusted value under the income method and the market method.
We find HML's conclusions as to the unadjusted values under these
two methods reasonable, and we conclude that the unadjusted value
under the income method is $8,109,000 and under the market method
is $10,410,000. Furthermore, we conclude each method deserves
equal weight.
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