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for shares in a closely held corporation. See Estate of Stevens
v. Commissioner, supra. Because the inability to control a
closely held corporation influences the marketability of the
investment, there is sometimes some overlap between the two
discounts. See Estate of Andrews v. Commissioner, supra at 952.
We have wide discretion in accepting expert testimony. See
Helvering v. National Grocery Co., 304 U.S. 282, 294-295 (1938).
We examine the expert’s qualifications and compare his or her
testimony with all other credible evidence in the record. We may
accept or reject an expert’s opinion entirely or pick and choose
the portions of the opinion we find reliable. See id.; Seagate
Tech., Inc., & Consol. Subs. v. Commissioner, 102 T.C. 149, 186
(1994); Estate of Newhouse v. Commissioner, 94 T.C. 193, 218
(1990); Parker v. Commissioner, 86 T.C. 547, 562 (1986).
At trial, Mr. Schneider accepted Mr. Wahlgren’s conclusion
that the fair market value of the Company stock on a minority
basis, but before consideration of the discount for lack of
marketability, was $46.24 per share at the time of transfer.2
From that figure, Mr. Wahlgren opined that a 65.77-percent
marketability discount was appropriate,3 while Mr. Schneider
2 Mr. Schneider, in his report, failed to account for
interest and principal recovered from loans previously charged
off on the books of the Bank.
3 References to marketability discount are to the discount
for lack of marketability.
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