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of any part of such an opinion, see Estate of Davis v. Commis-
sioner, supra; Parker v. Commissioner, 86 T.C. 547, 562 (1986).
We also may reject the opinion of an expert witness in its
entirety. See Palmer v. Commissioner, 523 F.2d 1308, 1310 (8th
Cir. 1975), affg. 62 T.C. 684 (1974); Estate of Davis v. Commis-
sioner, supra.
The parties and their respective stock valuation experts
agree that, in ascertaining the fair market value of decedent's
interest in Marrero Land on the valuation date, it is necessary,
inter alia, to determine as of that date the aggregate fair
market value of Marrero Land's assets and the aggregate amount of
its liabilities in order to calculate its net asset value as of
that date. Based on the stipulations of the parties, we have
found that as of the valuation date the aggregate fair market
value of Marrero Land's assets, excluding the remaining unim-
proved real properties, was $50,643,118, and the parties agree
that the aggregate liabilities of the Company as of that date
totaled $15,943,694. Although the parties did not stipulate the
fair market value on the valuation date of each of the remaining
unimproved real properties, they did stipulate that the aggregate
value of those properties on that date without regard to an
absorption discount is $20,366,470.
According to the estate, in order to arrive at the aggregate
fair market value of the remaining unimproved real properties,
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