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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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