Estate of Beatrice Ellen Jones Dunn - Page 8




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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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