- 170 -
217; Estate of Hall v. Commissioner, 92 T.C. at 338. We have
rejected expert opinion based on conclusions that are unexplained
or contrary to the evidence. See Knight v. Commissioner, 115
T.C. 506 (2000); Rose v. Commissioner, 88 T.C. 386, 401 (1987),
affd. 868 F.2d 851 (6th Cir. 1989); Compaq Computer Corp. v.
Commissioner, T.C. Memo. 1999-220.
Where necessary, we may reach a determination of value based
on our own examination of the evidence in the record. See Lukens
v. Commissioner, 945 F.2d 92, 96 (5th Cir. 1991)(citing Silverman
v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C.
Memo. 1974-285); Ames v. Commissioner, T.C. Memo. 1990-87, affd.
without published opinion 937 F.2d 616 (10th Cir. 1991). Where
experts offer divergent estimates of fair market value, we decide
what weight to give those estimates by examining the factors they
used in arriving at their conclusions. See Casey v.
Commissioner, 38 T.C. 357, 381 (1962). We have broad discretion
in selecting valuation methods, see Estate of O’Connell v.
Commissioner, 640 F.2d 249, 251 (9th Cir. 1981), affg. on this
issue and revg. in part T.C. Memo. 1978-191, and in determining
the weight to be given the facts in reaching our conclusions,
inasmuch as “finding market value is, after all, something for
judgment, experience, and reason”, Colonial Fabrics, Inc. v.
Commissioner, 202 F.2d 105, 107 (2d Cir. 1953), affg. a
Memorandum Opinion of this Court. While we may accept the
opinion of an expert in its entirety, see Buffalo Tool & Die Mfg.
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