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condition of the business.
(d) The earning capacity of the company.
(e) The dividend-paying capacity.
(f) Whether or not the enterprise has goodwill or
other intangible value.
(g) Sales of the stock and the size of the block
of stock to be valued.
(h) The market price of stocks of corporations
engaged in the same or a similar line of business
having their stocks actively traded in a free and open
market, either on an exchange or over-the-counter.
[Rev. Rul. 59-60, 1959-1 C.B. at 238-239.]
Both parties relied on the reports and testimony of expert
witnesses to assign values to the consideration received by Cyril
and the property interest transferred by Cyril. 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, supra. 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). Because valuation necessarily results in an
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