Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 24

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          our own examination of the evidence in the record.  Lukens v.               
          Commissioner, 945 F.2d 92, 96 (5th Cir. 1991) (citing Silverman             
          v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C.               
          Memo. 1974-285); Ames v. Commissioner, T.C. Memo. 1990-87.  Where           
          experts offer divergent estimates of fair market value, we decide           
          what weight to give these estimates by examining the factors they           
          used in arriving at their conclusions.  Casey v. Commissioner, 38           
          T.C. 357, 381 (1962).  We have broad discretion in selecting                
          valuation methods, Estate of O'Connell v. Commissioner, 640 F.2d            
          249, 251 (9th Cir. 1981), affg. on this issue and revg. in part             
          T.C. Memo. 1978-191, and the weight to be given the facts in                
          reaching our conclusion because “finding market value is, after             
          all, something for judgment, experience, and reason”, Colonial              
          Fabrics, Inc. v. Commissioner, 202 F.2d 105, 107 (2d Cir. 1953),            
          affg. a Memorandum Opinion of this Court dated January 22, 1951.            
          Moreover, while we may accept the opinion of an expert in its               
          entirety, Buffalo Tool & Die Manufacturing Co. v. Commissioner,             
          74 T.C. 441, 452 (1980), we may be selective in the use of any              
          part of such opinion, or reject the opinion in its entirety,                
          Parker v. Commissioner, supra at 561.  Finally, because valuation           
          necessarily results in an approximation, the figure at which this           
          Court arrives need not be one as to which there is specific                 
          testimony if it is within the range of values that may properly             
          be arrived at from consideration of all the evidence.  Silverman            
          v. Commissioner, supra at 933; Alvary v. United States, 302 F.2d            
          790, 795 (2d Cir. 1962).                                                    


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