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“‘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. Expert testimony
sometimes aids the Court in determining value; 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 Anderson v. Commissioner,
supra at 249; Estate of Newhouse v. Commissioner, supra at 217;
Estate of Hall v. Commissioner, 92 T.C. 312, 338 (1989). 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)). Moreover, while we may accept the opinion of
an expert in its entirety, see Buffalo Tool & Die Manufacturing
Co. v. Commissioner, 74 T.C. at 452, we may be selective in the
use of any part of such opinion or reject the opinion in its
entirety, see Seagate Tech., Inc. v. Commissioner, 102 T.C. 149,
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