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chairman of the board, and David Faris, a Korbel assistant vice
president. Formerly, Mr. Faris was a partner in the tax
department of Pisenti & Brinker, C.P.A.s. In that role, he
oversaw the preparation of Korbel’s income tax returns, the
estate tax return filed on behalf of decedent’s estate, and the
valuation, for gift tax purposes, of the stock that, in 1989,
decedent transferred in trust for the benefit of her
grandchildren. Mr. Heck did not testify as to the value of
the shares, and, although Mr. Faris testified that the Pisenti &
Brinker gift tax valuation, in part, formed the basis for the
value of the shares set forth on the estate tax return, it is the
value arrived at by Dr. Bajaj, not the value on the return, that
petitioner urges us to adopt.
In deciding valuation cases, courts often look to the
opinions of expert witnesses. Nonetheless, we are not bound by
the opinion of any expert witness, and we may accept or reject
expert testimony in the exercise of our sound judgment.
Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938); Estate
of Newhouse v. Commissioner, supra at 217. Although we may
accept the opinion of an expert in its entirety, see Buffalo Tool
& Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980),
we may be selective in determining what portions of an expert’s
opinion, if any, to accept, Parker v. Commissioner, 86 T.C. 547,
562 (1986). Finally, because valuation necessarily involves an
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