- 21 -
proper regard to all other credible evidence in the record. See
Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir. 1986), affg.
in part and revg. in part on another issue T.C. Memo. 1983-200;
Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir.
1973), affg. 54 T.C. 493 (1970). We may accept or reject an
expert's opinion in toto, or we may pick and choose the portions
of the opinion which we choose to adopt. See Helvering v.
National Grocery Co., 304 U.S. at 294-295; Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285; Parker v. Commissioner, 86 T.C. 547, 562 (1986); see
also Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506.
The mere fact that the position of one party may be unsupported
by expert testimony does not necessarily mean that the other
party's position that is so supported will prevail. See Estate
of Scanlan v. Commissioner, supra.
Mr. Tack's reports do not persuade us that the value of the
estate's stock was the amount stated therein. He relied
repeatedly on the unverified representations of Seminole's
management, and we are unable to verify the accuracy or
completeness of those representations. He also relied on faulty
assumptions to arrive at his value, neglected to analyze key
indicia of value (including Seminole's certificate of
incorporation and bylaws), and assumed erroneously that the sales
by Mr. Hoffman and Ms. Branch were at arm's length. Mr. Tack
took into account the price at which Mr. Hoffman and Ms. Branch
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