Epco, Inc. and Subsidiaries - Page 19




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          sell and having a reasonable knowledge of the relevant facts at             
          the time, would not have sold the sewer line on which Imperial              
          and others had just spent $350,000 to a buyer for only $80,000 at           
          the time of completion in April 1989.                                       
               Furthermore, the portions of Mr. Jones' testimony concerning           
          cost overruns in the construction of the sewer line are vague and           
          unsupported by the record.                                                  
               Finally, petitioner contends that Mr. Jones' testimony makes           
          a prima facie case for petitioner's valuation which then must be            
          rebutted by respondent.  We reject this contention.  It is well             
          established that this Court is not required to accept the                   
          testimony of alleged expert witnesses as "gospel" and that we are           
          entitled to evaluate testimony by our own judgment and in light             
          of the entire record.  See Cupler v. Commissioner, 64 T.C. 946,             
          956 (1975).  Mr. Jones' report and testimony is therefore of                
          little use to this Court in such valuation.                                 
          Cost Method of Valuation                                                    
               Respondent contends that the sewer line should be valued by            
          use of the cost method.4  Respondent contends that the best                 

               4    It is unclear from the record, but respondent seems to            
          have, at times, equated "replacement cost" with historical cost.            
          The replacement cost method of valuation uses the projected cost            
          of replacement to value property.  The replacement method bears             
          some resemblance to the historical cost method in that the                  
          replacement cost method typically uses actual cost figures as a             
          primary information source.  We believe, however, that in this              
          case, actual cost, and not replacement cost, is the better                  
                                                             (continued...)           




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