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settlement or the presiding judge, we rely on our prior findings
with respect to the intentions of the parties. As we held
earlier, the guaranty obligation was not intended to survive
decedent’s death, and we do not find evidence establishing that
the guaranteed payments were in the form of lump-sum alimony.
Accordingly, we hold that the guaranty obligation is not
includable in decedent’s gross estate.
B. Property Interests Held by Decedent at Time of Death
Both parties relied on the reports and testimony of experts
to determine the value of decedent’s property interests for
estate tax purposes. While expert opinions may assist in
evaluating a claim, 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). Where experts offer conflicting estimates of fair market
value, we examine the factors they used and decide the
appropriate weight given to each. See Casey v. Commissioner, 38
T.C. 357, 381 (1962). We may accept the opinion of an expert in
its entirety, see Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980), or we may be selective in
the use of any portion, see Parker v. Commissioner, 86 T.C. 547,
562 (1986).
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