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govern the value of the other 50-share block. We proceed
likewise in our analysis.
Valuation of stock for tax purposes is a matter of “pure
fact” and one to be decided by considering all circumstances
connected with the corporation; there is no one universally
applicable formula. Hamm v. Commissioner, 325 F.2d 934, 938 (8th
Cir. 1963), affg. T.C. Memo. 1961-347; see Estate of Goodall v.
Commissioner, 391 F.2d 775, 786 (8th Cir. 1968), affg. in part
and revg. in part T.C. Memo. 1965-154.
Respondent, who determined in the notice of deficiency that
the value of decedent’s 50 shares of C&L Bailey stock was
$451,263, now contends that the value is $415,319. Petitioner,
who originally reported the value of the 50 shares as $370,708,
contends on brief that the value is only $194,565.
In support of their positions, each party relies on expert
testimony. We evaluate expert opinions in light of all the
evidence in the record and may accept or reject expert testimony,
in whole or in part, according to our own judgment. See
Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938); Estate
of Ford v. Commissioner, 53 F.3d 924, 927 (8th Cir. 1995), affg.
T.C. Memo. 1993-580; Palmer v. Commissioner, 523 F.2d 1308, 1310
(8th Cir. 1975), affg. 62 T.C. 684 (1974); Shepherd v.
Commissioner, 115 T.C. 376 (2000), affd. 283 F.3d 1258 (11th Cir.
2002).
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