Estate of Mary D. Maggos - Page 28




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          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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