Estate of Charles a. Boratello, Deceased, C. Norman Borgatello and Josephine E. Donnelly, Co-Executors, and C. Norman Borgatello, Successor Trustee to the Charles A. Borgatello Living Trust - Page 12

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            Memo. 1974-285; Estate of Davis v. Commissioner, 110 T.C. 530,                             
            538 (1998).  Where experts offer divergent estimates of fair                               
            market value, we decide what weight to give these estimates by                             
            examining the factors they used in arriving at their conclusions.                          
            See Casey v. Commissioner, 38 T.C. 357, 381 (1962).                                        
                  We have broad discretion in selecting valuation methods, see                         
            Estate of O'Connell v. Commissioner, 640 F.2d 249, 251 (9th Cir.                           
            1981), affg. on this issue and revg. in part T.C. Memo. 1978-191,                          
            and the weight to be given the facts in reaching our conclusion                            
            because "finding market value is, after all, something for                                 
            judgment, experience, and reason", Colonial Fabrics, Inc. v.                               
            Commissioner, 202 F.2d 105, 107 (2d Cir. 1953), affg. a                                    
            Memorandum Opinion of this Court.  Moreover, while 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), we                             
            may be selective in the use of any part of such opinion, or                                
            reject the opinion in its entirety, see Parker v. Commissioner,                            
            supra at 561.  Because valuation necessarily results in an                                 
            approximation, the figure at which this Court arrives need not be                          
            one as to which there is specific testimony if it is within the                            
            range of values that may properly be arrived at from                                       
            consideration of all the evidence.  See Estate of O'Connell v.                             

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