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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
stock.
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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