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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).
Petitioner’s experts were William H. Frazier (Mr. Frazier)
of Howard Frazier Barker Elliot, Inc., and Shannon P. Pratt (Mr.
Pratt) of Willamette Management Associates. Respondent’s expert
was Carmen R. Eggleston (Ms. Eggleston) of Price Waterhouse LLP.
All three experts authored reports and testified at trial. Mr.
Frazier’s report estimated the fair market value of the stock.
Ms. Eggleston’s report critiqued Mr. Frazier’s report but did not
independently value the stock. Mr. Pratt’s report also did not
independently value the stock in issue but instead reviewed Mr.
Frazier’s report and critiqued Ms. Eggleston’s report.
I. Weighting the Values
Mr. Frazier calculated an earnings-based value using
capitalized net income and an asset-based value using what he
considered to be the liquidation value of the company. For his
final value, he gave each of these a weight of 50 percent.
Respondent argues that no weight should be given to earnings-
based value and moreover that the correct asset-based value is
fair market value of the underlying assets rather than
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