Estate of Rebecca A. Wineman - Page 26




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          on comparing qualifications, and listing them would unduly                  
          lengthen this opinion.  The focus of our opinion is on the degree           
          to which the experts’ opinions are supported by the evidence.               
               In reviewing the conclusions of each expert, we may accept             
          or reject expert testimony according to our own judgment, and we            
          may be selective in deciding what parts of an expert's opinion,             
          if any, we will accept.  See Parker v. Commissioner, 86 T.C. 547,           
          562 (1986).  Conclusory opinions that are unexplained or contrary           
          to the factual evidence will be rejected.  See Compaq Computer              
          Corp. v. Commissioner, T.C. Memo. 1999-220.                                 
               B.   Petitioner's Expert                                               
               Mr. Gilman appraised decedent's real estate interests in               
          conjunction with the filing of petitioner's Form 706.  He also              
          prepared an update of that appraisal as an expert report in                 
          conjunction with this litigation.  Mr. Gilman used the sales                
          comparison approach11 to determine the fair market value of                 
          decedent's interest in the properties.  Mr. Gilman chose nine               
          properties that he determined were comparable to the ranch                  



               11The sales comparison approach, also known as the                     
          comparable sales or market data approach, is “‘generally the most           
          reliable method of valuation, the rationale being that the market           
          place is the best indicator of value, based on the conflicting              
          interests of many buyers and sellers.’”  Estate of Spruill v.               
          Commissioner, 88 T.C. 1197, 1229 n.24 (1987) (quoting Estate of             
          Rabe v. Commissioner, T.C. Memo. 1975-26, affd. without published           
          opinion 566 F.2d 1183 (9th Cir. 1977)).                                     





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