Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 23

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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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