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settlement agreement, as an arm's-length transaction, is the best
indicator of fair market value.
A. Expert Opinions
As is customary in valuation cases, the parties rely
primarily on expert opinion evidence to support their contrary
valuation positions. We evaluate the opinions of experts in
light of the demonstrated qualifications of each expert and all
other evidence in the record. Anderson v. Commissioner, supra;
Parker v. Commissioner, 86 T.C. 547, 561 (1986). We have broad
discretion to evaluate "`the overall cogency of each expert's
analysis.’" Sammons v. Commissioner, 838 F.2d 330, 334 (9th Cir.
1988) (quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part T.C. Memo. 1983-200),
affg. in part and revg. in part on another ground T.C. Memo.
1986-318. Expert testimony sometimes aids the Court in
determining values, and sometimes it does not. See, e.g., Estate
of Halas v. Commissioner, 94 T.C. 570, 577 (1990); Laureys v.
Commissioner, 92 T.C. 101, 129 (1989) (expert testimony is not
useful when the expert is merely an advocate for the position
argued by one of the parties). We are not bound by the formulas
and opinions proffered by an expert witness and will accept or
reject expert testimony in the exercise of sound judgment.
Helvering v. National Grocery Co., supra at 295; Anderson v.
Commissioner, supra at 249; Estate of Newhouse v. Commissioner,
supra at 217; Estate of Hall v. Commissioner, supra at 338.
Where necessary, we may reach a determination of value based on
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