- 8 - 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 thanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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