Robert T. and Mary F. Gow - Page 20




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          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.                              






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