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are about 19-percent brick.
OPINION
A. The Fair Market Value of the Apartment Building
We must decide the fair market value of the apartment
building transferred by petitioner corporation to petitioner on
August 10, 1993. Fair market value is the price at which the
property would change hands between a willing buyer and a willing
seller, neither being under any compulsion to buy or to sell and
both having reasonable knowledge of the relevant facts. See
United States v. Cartwright, 411 U.S. 546, 551 (1973); Propstra
v. United States, 680 F.2d 1248, 1251 (9th Cir. 1982); sec.
20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs.
Respondent contends that the fair market value of the apartment
building was $139,900 on August 10, 1993. Petitioners contend
that the fair market value was $106,000.
B. Expert Witnesses
Both parties relied on expert witnesses. We may accept or
reject expert testimony according to our own judgment, and we may
be selective in deciding what parts of an expert’s opinion, if
any, we accept. See Helvering v. National Grocery Co., 304 U.S.
282, 295 (1938); Parker v. Commissioner, 86 T.C. 547, 562 (1986).
Martyn C. Glen (Glen) and Jack L. Wolff (Wolff) testified for
petitioners. Edwin A. Kurek (Kurek) testified for respondent.
The experts agreed that the comparable sales method was the best
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