Estate of Richie C. Heck, Deceased , Gary Heck, Special Administrator - Page 14




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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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