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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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