- 26 - 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)).Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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