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offer divergent estimates of fair market value, we decide the
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 may reject in its entirety an opinion
provided under circumstances that undermine its credibility.
See, e.g., Snyder v. Commissioner, 86 T.C. 567, 584-585 (1986);
Chiu v. Commissioner, 84 T.C. 722 (1985); Dean v. Commissioner,
83 T.C. 56, 75 (1984).
Malina has been a member of the Appraisers Association of
America, Inc., since 1964 with a specialty in Oriental art. His
investigation of the Kesslers consisted of telephone
conversations with Seymour Kessler, a review of trade periodicals
offering Kesslers for retail sale, and a review of the
Brueggemann inventory. Malina erroneously referred to the
Kesslers as “covers”-–unaware of or ignoring the distinction
between covers and pages. He also claims to have analyzed the
market for first day covers. In his report, he listed the
Kesslers, assigning a value to each lot. Malina’s analysis was
limited to an unsupported assertion that respondent’s examining
agent significantly undervalued the Kesslers and to his
contention that the Kesslers were valuable because they were
suitable for framing.
With respect to the religious articles, Malina adopted the
values set forth in his 1993 valuation. He provided only a
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