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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.
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