Estate of Duilio Costanza - Page 12

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          Bristol West retail office properties.  We have wide discretion             
          when it comes to accepting expert testimony.  Sometimes, an                 
          expert will help us decide a case.  See, e.g ., Booth v.                    
          Commissioner, 108 T.C. 524, 573 (1997); Trans City Life Ins. Co.            
          v. Commissioner, 106 T.C. 274, 302 (1996). Other times, he or she           
          will not. See, e.g., Mandelbaum v. Commissioner, T.C. Memo. 1995-           
          255, affd. without published opinion 91 F.3d 124 (3d Cir. 1996).            
          We weigh an expert's testimony in light of his or her                       
          qualifications and with proper regard to all other credible                 
          evidence in the record.  See Helvering v. National Grocery Co.,             
          304 U.S. 282, 294 (1938).                                                   
               Petitioner claimed that the value of the Latina restaurant             
          property was $330,000 on December 15, 1992.  Petitioner did not             
          present testimony to support that value.  Petitioner instead                
          relied upon the written appraisal prepared in 1991 by Walter P.             
          Schmidt incident to a valuation of the estate of decedent’s wife.           
          Mr. Schmidt’s list of qualifications indicates that he has 2                
          years of college education at Flint Junior College and a real               
          estate certificate from the University of Michigan.  He is a                
          "State Certified Real Estate Appraiser" and has listed                      
          substantial experience in valuing real estate.                              
               Respondent’ expert, Mark Bollinger, studied packaging                  
          engineering at Michigan State University.  He is a member of the            
          Appraisal Institute, and he also is a "State Certified Real                 

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