- 50 - Cronkite, CA, ASA, prepared reports on behalf of the estate,1 and John A. Thomson, ASA, MAI, prepared reports on behalf of respondent. We evaluate expert testimony in light of all evidence contained in the record and may accept or reject the proffered opinions, in whole or in part, according to our own judgement. Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938); Shepherd v. Commissioner, 115 T.C. at 390. In particular, “‘The persuasiveness of an expert’s opinion depends largely upon the disclosed facts on which it is based.’” Shepherd v. Commissioner, supra at 390 (quoting Estate of Davis v. Commissioner, 110 T.C. 530, 538 (1998)). The respective appraisals by Mr. Cronkite and Mr. Thomson of HFLP’s net asset value are summarized below: ASSET Mr. Cronkite Mr. Thomson Cash $2,517 $2,517 Marketable Securities 832,299 832,299 (M.L. Stern & Co. Account) California Tax-Free Income Fund 63,817 63,817 (M.L. Stern & Co. Account) Franklin AGE High Income Fund 69,130 69,130 Franklin California Tax-Free Fund 249,979 249,979 Putnam American Government Income Fund 71,017 71,017 1 The report submitted on behalf of the estate valuing HFLP as of February 1, 1995, contains a certification signed by both Mr. Cronkite and Helena Nam Reich, ASA. However, because it is Mr. Cronkite who testified at trial, whom both parties refer to as petitioner’s expert, and whose qualifications have been stipulated by the parties, we adopt a similar convention of referring solely to Mr. Cronkite.Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
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