- 28 -
Parker v. Commissioner, 86 T.C. 547, 561 (1986). We have broad
discretion to evaluate the overall cogency of each expert’s
analysis. See Sammons v. Commissioner, 838 F.2d 330, 334 (9th
Cir. 1988), affg. in part and reversing in part T.C. Memo. 1986-
318. We are not bound by the formulas and opinions proffered by
an expert witness and will accept or reject expert testimony in
the exercise of sound judgment. See Helvering v. National
Grocery Co., supra at 295; Anderson v. Commissioner, supra at
249. We may reach a determination of value based on our own
examination of the evidence in the record. See Lukens v.
Commissioner, 945 F.2d 92, 96 (5th Cir. 1991) (citing Silverman
v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C.
Memo. 1974-285). Where experts offer divergent estimates of fair
market value, we decide what weight to give these estimates by
examining the factors they used in arriving at their conclusions.
See Casey v. Commissioner, 38 T.C. 357, 381 (1962). We have
broad discretion in selecting valuation methods. See Estate of
O’Connell v. Commissioner, 640 F.2d 249, 251 (9th Cir. 1981),
affg. on this issue and revg. in part T.C. Memo. 1978-191.
Moreover, while 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), we may be selective in the
use of any part of such opinion, or reject the opinion in its
entirety, see Parker v. Commissioner, supra at 561. Finally,
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