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Fair market value is defined as “‘the price at which the
property would change hands between a willing buyer and a willing
seller, neither being under any compulsion to buy or to sell and
both having reasonable knowledge of relevant facts.’” United
States v. Cartwright, 411 U.S. 546, 551 (1973) (quoting sec.
20.2031-1(b), Estate Tax Regs.). Expert opinion sometimes aids
the Court in determining valuation; other times, it does not.
See Laureys v. Commissioner, 92 T.C. 101, 129 (1989). We
evaluate such opinions in light of the demonstrated
qualifications of the expert and all other evidence of value in
the record. See Estate of Newhouse v. Commissioner, 94 T.C. 193,
217 (1990). We are not bound, however, by the opinion of any
expert witness when that opinion contravenes our judgment. See
id. We may accept the opinion of an expert in its entirety, see
Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.
441, 452 (1980), or we may be selective in the use of any portion
thereof, see Parker v. Commissioner, 86 T.C. 547, 562 (1986).
The best method to value a corporation’s stock is to rely on
actual arm’s-length sales of the stock within a reasonable period
of the valuation date. See Estate of Andrews v. Commissioner, 79
T.C. 938, 940 (1982). There were no such sales for JFI or FNBW.
Thus, all of the experts used less direct methods of valuation.
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