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hypothetical. See Propstra v. United States, 680 F.2d 1248,
1251-1252 (9th Cir. 1982); Estate of Robinson v. Commissioner, 69
T.C. 222, 225 (1977). Fair market value of property as of any
given date is a question of fact to be determined from the entire
record. See Lio v. Commissioner, 85 T.C. 56, 66 (1985), affd.
sub nom. Orth v. Commissioner, 813 F.2d 837 (7th Cir. 1987).
While we must consider the entire record, we have broad
discretion in deciding which facts are most important in reaching
a decision because “finding market value is, after all, something
for judgment, experience, and reason”. Colonial Fabrics, Inc. v.
Commissioner, 202 F.2d 105, 107 (2d Cir. 1953), affg. a
Memorandum Opinion of this Court dated Jan. 22, 1951.
The determinations of value in respondent's statutory notice
of deficiency are presumptively correct. See Welch v. Helvering,
290 U.S. 111 (1933). Petitioner bears the burden of proving that
the fair market values of the properties are less than those
determined by respondent. See Rule 142(a). Respondent bears the
burden of proof with respect to any increases in value beyond
those determined in the notice of deficiency. See id.
In support of their positions, both parties presented expert
testimony. Both expert witnesses are appraisers: Leslie J.
Gilman (Mr. Gilman) for petitioner and David F. Hamel (Mr. Hamel)
for respondent. We do not list or discuss here the
qualifications of the experts, because our decision is not based
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