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applications to insure that the collateral provided adequate
security.
Though we find that Mr. Jones has no expertise in the
specific area of valuing sewer lines, we do find that Mr. Jones
has professional knowledge acquired from prior valuations using
acceptable methods of valuation; i.e., income capitalization.
We consider his testimony in that light and accept his
testimony under those circumstances. We must now decide whether
Mr. Jones' general valuation experience is helpful to this Court
in arriving at the fair market value of the sewer line in
question.
Though expert opinion is admissible and relevant to a
valuation question and is intended to help the Court understand
areas requiring specialized training, it does not always aid the
Court in determining the value of property. See Laureys v.
Commissioner, 92 T.C. 101, 129 (1989).
This Court will evaluate expert testimony in light of the
demonstrated qualifications of the expert and on the basis of all
other credible evidence in the record. See Estate of Newhouse v.
Commissioner, 94 T.C. at 217. This Court is the trier of fact
and is not bound by expert opinion when that opinion contravenes
our judgment. See Estate of Newhouse v. Commissioner, supra.
Moreover, because valuation is necessarily an approximation, it
is not required that the value we determine be one as to which
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