- 37 -
570, 577 (1990); Laureys v. Commissioner, 92 T.C. 101, 129
(1989). 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. See Helvering v. National
Grocery Co., 304 U.S. at 295; Anderson v. Commissioner, 250 F.2d
at 249; Estate of Newhouse v. Commissioner, 94 T.C. at 217;
Estate of Hall v. Commissioner, 92 T.C. at 338. Where necessary,
we may reach a determination of value based on our own
examination of the evidence in the record. See 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, affd.
without published opinion 937 F.2d 616 (10th Cir. 1991). 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. See Casey v.
Commissioner, 38 T.C. 357, 381 (1962). We have broad discretion
in selecting valuation methods, see 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 in determining
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. Moreover, while we may accept
the opinion of an expert in its entirety, Buffalo Tool & Die
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