Estate of John L. Baird - Page 7




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          accord with this Court’s Rules of Practice and Procedure.                   
          Respondent’s expert, however, was found not to be specifically              
          qualified to assist the trier of fact (Court) on the question of            
          the discount to be applied, if any, to a fractional interest in             
          timberland.                                                                 
               It is noted that the parties stipulated the fair market                
          value of the undivided fee interest.  Further, the parties agree            
          that there should be some discount because of the nature of the             
          decedents’ ownership.  The only question we consider is the                 
          amount of the discount applicable to the fractional interests               
          held by the decedents at their dates of death.                              
               Valuation of an interest in property is a highly factual               
          pursuit, and it is within the Court’s discretion to evaluate the            
          cogency of the expert witnesses’ conclusions or opinions.                   
          Sammons v. Commissioner, supra.  Opinions of experts are                    
          evaluated in light of each expert’s demonstrated qualifications             
          and the evidence in the record.  Estate of Davis v. Commissioner,           
          110 T.C. 530, 538 (1998) (and cases cited therein).  We may                 
          accept or reject all or part of an expert’s opinion.  Id.                   
          The Estates’ Expert Witnesses                                               
               The estates rely on three expert witnesses to support their            
          proposed discounts for the partial interests under consideration.           
          Respondent attempted to expose the weaknesses of the estates’               
          experts in order to show that estates’ proposed discounts are               
          excessive.                                                                  




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