- 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.
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