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which the trier of fact must weigh all relevant evidence and draw
appropriate inferences and conclusions. See Commissioner v.
Scottish Am. Inv. Co., 323 U.S. 119, 123-125 (1944).
Real estate valuation is a question of fact to be resolved
on the basis of the entire record. See Ahmanson Found. v. United
States, 674 F.2d 761, 769 (9th Cir. 1981); Estate of Fawcett v.
Commissioner, 64 T.C. 889, 898 (1975). After determining the
gross value of the property, there may be adjustments upward or
downward for such factors affecting value as minority discounts,
discounts for lack of marketability, control premiums, and
fractional interest discounts. See Estate of Andrews v.
Commissioner, 79 T.C. 938, 953-956 (1982) (minority discount);
Estate of Piper v. Commissioner, 72 T.C. 1062, 1084-1086 (1979)
(discount for lack of marketability for stock); Estate of
O’Keeffe v. Commissioner, T.C. Memo. 1992-210 (blockage discounts
for works of art); Estate of Salsbury v. Commissioner, T.C. Memo.
1975-333 (control premiums).
Valuation is an inexact process. See Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980). As
the trier of fact, we may use experts to assist in deciding upon
a value, but we are not bound by those experts’ views or
opinions. See Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976), affg. T.C. Memo. 1974-285; Chiu v. Commissioner, 84
T.C. 722, 734 (1985). One expert may be persuasive on a
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