- 20 - 323 U.S. 119, 123-125 (1994); Estate of Jung v. Commissioner, 101 T.C. 412, 423-424 (1993); Skripak v. Commissioner, 84 T.C. 285, 320 (1985). However, future events that are reasonably foreseeable at the valuation date may be considered in determining fair market value. See Estate of Newhouse v. Commissioner, supra at 218. Both respondent and petitioners rely upon the report and testimony of their respective expert witnesses to establish the value of the shares of WVI’s stock awarded to Dr. Gow. We weigh the expert’s testimony in light of the expert’s qualifications as well as other credible evidence. See Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir. 1973), affg. 54 T.C. 493 (1970); Estate of Newhouse v. Commissioner, supra at 217. We are not bound by the opinion of any expert witness; we may reach a decision as to the value of property based upon our own analysis of all the evidence in the record, see Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo. 1974-285, using all of one party’s expert analysis, or selectively using any portion of either analysis, see Estate of Simplot v. Commissioner, supra at 155; Parker v. Commissioner, 86 T.C. 547, 562 (1986); Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980). Additionally, we may derive the fair market value of property from within a permissible range of values that may be arrived at from consideration of all the evidence. See Silverman v. Commissioner, supra; Estate of Simplot v. Commissioner, supra.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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