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qualifications of each expert and all other evidence in the
record. See Estate of Christ v. Commissioner, 480 F.2d 171, 174
(9th Cir. 1973), affg. 54 T.C. 493 (1970); Parker v.
Commissioner, 86 T.C. 547, 561 (1986). We have broad discretion
to evaluate "'the overall cogency of each expert's analysis.'"
Sammons v. Commissioner, 838 F.2d 330, 334 (9th Cir. 1988)
(quoting Ebben v. Commissioner, 783 F.2d 906, 909 (9th Cir.
1986), affg. in part and revg. in part T.C. Memo. 1983-200),
affg. in part and revg. in part on another ground T.C. Memo.
1986-318.
Expert testimony sometimes aids the Court in determining
values, and sometimes it does not. See, e.g., Estate of Halas v.
Commissioner, 94 T.C. 570, 577 (1990); Laureys v. Commissioner,
92 T.C. 101, 129 (1989) (stating that expert testimony is not
useful when the expert is merely an advocate for the position
argued by one of the parties). We are not bound by the formulas
and opinions proffered by an expert witness and shall accept or
reject expert testimony in the exercise of sound judgment. See
Helvering v. National Grocery Co., 304 U.S. 282, 295 (1938);
Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990).
Where necessary, we may reach a determination of value based on
our own examination of the evidence in the record. See Silverman
v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C.
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