Estate of James J. Renier, Deceased, Kent L. Renier and Dubuque Bank & Trust Company, Co-Executors - Page 8

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               Expert opinions sometimes aid the Court in determining                 
          valuation; other times, they do not.  See Laureys v.                        
          Commissioner, 92 T.C. 101, 129 (1989).  We evaluate such opinions           
          in light of each expert’s qualifications and all other evidence             
          of value in the record.  See Estate of Newhouse v. Commissioner,            
          94 T.C. 193, 217 (1990).  We are not bound, however, to accept              
          any expert opinion when that opinion contravenes our judgment.              
          See id.  We may accept an expert opinion in its entirety, see               
          Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.               
          441, 452 (1980), or we may selectively use any portion thereof,             
          see Parker v. Commissioner, 86 T.C. 547, 562 (1986).                        
               A.  The Experts                                                        
               Respondent presented the testimony and expert report of                
          Leonard J. Sliwoski to support the deficiency determination.  The           
          estate presented the testimony and expert reports of Yale Kramer,           
          of McGladrey & Pullen, LLP, and Allan L. R. Lannom, of Houlihan             
          Valuation Advisors, to support the reported value of Renier’s               
               Respondent’s expert, Mr. Sliwoski, considered an asset,                
          income, and market approach to value Renier and concluded that an           
          income approach, using the capitalized value of expected future             
          earnings, should be used exclusively.  Based on this approach,              
          Mr. Sliwoski concluded that Renier had a total value of                     
          $1,847,698 and that decedent’s 88.4 percent interest therein had            
          an approximate value of $1,633,000 on the valuation date.                   

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