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OPINION
I. Expert Opinions
As is customary in valuation cases, the parties rely
primarily on expert opinion evidence to support their contrary
valuation positions. We evaluate the opinions of experts in
light of their demonstrated qualifications and all other evidence
in the record. See Anderson v. Commissioner, 250 F.2d 242 (5th
Cir. 1957), affg. in part and remanding in part on another ground
T.C. Memo. 1956-178; Parker v. Commissioner, 86 T.C. 547, 561
(1986). We have broad discretion to evaluate “‘the overall
cogency of each expert’s analysis.’” Sammons v. Commissioner,
838 F.2d 330, 334 (9th Cir. 1988)(quoting Ebben v. Commissioner,
783 F.2d 906, 909 (9th Cir. 1986), affg. in part and revg. in
part T.C. Memo. 1983-200), affg. in part and revg. in part on
another ground T.C. Memo. 1986-318. Although expert testimony
usually helps the Court determine values, sometimes it does not,
particularly when the expert is merely an advocate for the
position argued by one of the parties. See, e.g., Estate of
Halas v. Commissioner, 94 T.C. 570, 577 (1990); Laureys v.
Commissioner, 92 T.C. 101, 129 (1989).
We are not bound by the formulas and opinions proffered by
an expert witness and will accept or reject expert testimony in
the exercise of sound judgment. See Helvering v. National
Grocery Co., 304 U.S. 282, 295 (1938); Anderson v. Commissioner,
250 F.2d at 249; Estate of Newhouse v. Commissioner, 94 T.C. at
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