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the economic substance of petitioner’s conveyance to the
partnership of his entire interest in the leased land. We have
not, however, aggregated the separate, indirect gifts to his
sons, John and William. See Estate of Bosca v. Commissioner,
T.C. Memo. 1998-251 (for purposes of the gift tax, each separate
gift must be valued separately), and cases cited therein; cf.
Estate of Bright v. United States, 658 F.2d 999 (5th Cir. 1981)
(rejecting family attribution in valuing stock for estate tax
purposes).
D. Valuation of the Leased Land
The parties rely on expert testimony to value petitioner’s
interest in the leased land at the time he transferred it to the
partnership. We evaluate expert opinions in light of all the
evidence in the record and may accept or reject the expert
testimony, in whole or in part, according to our own judgment.
See Helvering v. National Grocery Co., 304 U.S. 282, 295 (1938);
Estate of Mellinger v. Commissioner, 112 T.C. 26, 39 (1999).
“The persuasiveness of an expert’s opinion depends largely upon
the disclosed facts on which it is based.” Estate of Davis v.
Commissioner, 110 T.C. 530, 538 (1998). We may be selective in
our use of any part of an expert’s opinion. See id.
Petitioner presented testimony of three expert witnesses:
Mr. Norman W. Lipscomb (Lipscomb), Mr. Gene Dilmore (Dilmore),
and Mr. Harry L. Haney, Jr. (Haney).
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