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individual issues in the retail market, they must remove the
issues from their bindings, prepare them for sale, and locate
willing buyers for each date. The purchase price of a newspaper
collection in the wholesale market depends on a variety of
factors, including the condition, content, and date and title of
the newspapers. The value attributable to an individual issue
generally diminishes when it is sold as part of a collection.
Both parties relied on the reports and testimony of expert
witnesses for purposes of determining the appropriate market and
the fair market value of the donated Los Angeles and Chicago
newspapers. Valuation is an approximation derived from all the
evidence. See Helvering v. Safe Deposit & Trust Co., 316 U.S.
56, 66-67 (1942); Silverman v. Commissioner, 538 F.2d 927, 933
(2d Cir. 1976), affg. T.C. Memo. 1974-285; Estate of Davis v.
Commissioner, 110 T.C. 530, 537 (1998). The opinions of experts
are admissible and relevant to the issue of value, but the
opinions must be weighed in light of each expert’s qualifications
and all other relevant evidence of value. See Johnson v.
Commissioner, 85 T.C. 469, 477 (1985). We are not bound by these
opinions and may reach a decision based on our own analysis of
all the evidence in the record. See Helvering v. National
Grocery Co., 304 U.S. 282, 295 (1938); Estate of Newhouse v.
Commissioner, 94 T.C. 193, 217 (1990). We may accept the opinion
of an expert in its entirety, see Buffalo Tool & Die
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