- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011