Estate of Lynn M. Rodgers, deceased, First National Bank of Commerce, Executor - Page 19




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          Inc., located in New Orleans, Louisiana, and whom the Court                 
          qualified as a stock valuation expert.  Respondent relies on                
          (1) Frederick M. Guice, Sr. (Mr. Guice), a general real estate              
          appraiser certified by the State of Louisiana, who is employed by           
          Stephen L. Guice & Co., Inc., a real estate broker and appraisal            
          company located in New Orleans, Louisiana, and whom the Court               
          qualified as a real estate valuation expert; and (2) Philip W.              
          Moore (Mr. Moore), who is chairman of Moore Associates Valua-               
          tions, located in Jacksonville, Florida, and whom the Court                 
          qualified as a stock valuation expert.  Each of the experts                 
          prepared an initial expert report (expert report) and a rebuttal            
          expert report (rebuttal report).3                                           
               We evaluate the opinions of experts in light of the dem-               
          onstrated qualifications of each expert and all other evidence in           
          the record.  See Anderson v. Commissioner, supra at 249; Estate             
          of Davis v. Commissioner, 110 T.C. at 538.  We have broad dis-              
          cretion to evaluate "'the overall cogency of each expert's                  
          analysis.'"  Sammons v. Commissioner, 838 F.2d 330, 333 (9th Cir.           


               3Mr. Egan, the estate's real estate valuation expert, pre-             
          pared a rebuttal report with respect to the expert report of Mr.            
          Guice, respondent's real estate valuation expert, and Mr. Guice             
          prepared a rebuttal report with respect to the expert report of             
          Mr. Egan.  In addition, each of the estate's stock valuation                
          experts, Mr. Stryker and Mr. Chaffe, prepared a rebuttal report             
          with respect to the expert report of respondent's stock valuation           
          expert Mr. Moore, and Mr. Moore prepared one rebuttal report with           
          respect to the expert reports of Mr. Stryker and Mr. Chaffe.                





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