- 22 -                                         
               Mr. Weiksner valued the trust’s 49.04-percent interest in JPMS         
          common stock (1,226 shares) at $20,634,000 to $25,489,000, with a           
          midpoint value of $23,062,000.                                              
               Mr. McGraw’s comparative companies analysis resulted in a              
          $29.5 million value for the 1,226 shares of JPMS common stock.  His         
          discounted cashflow analysis resulted in a $27.2 million value for          
          the 1,226 shares of JPMS common stock.                                      
               Mr. Hanan determined an $81 million fair market value for the          
          1,226 shares of JPMS common stock under his comparable companies            
          analysis.  Although Mr. Hanan proposed an $81 million fair market           
          value for the 1,226 shares of JPMS common stock, he conceded that           
          because of a likely disagreement between the buyer/seller and Mr.           
          DeJoria over Mr. DeJoria’s compensation and the possibility of              
          litigation, the value of the subject stock could be as high as              
          $165.3 million and as low as $57.7 million.                                 
               Expert witness reports may help the Court understand an area           
          requiring specialized training, knowledge, or judgment.  Snyder v.          
          Commissioner, 93 T.C. at 534.  We may be selective in deciding what         
          part of an expert witness’s report we will accept.  Helvering v.            
          Natl. Grocery Co., 304 U.S. 282, 295 (1938); Parker v.                      
          Commissioner, 86 T.C. 547, 561 (1986).  The purpose of expert               
          testimony is to assist the trier of fact to understand evidence             
          that will determine the fact in issue.  Laureys v. Commissioner, 92         
          T.C. 101, 127-129 (1989).  An expert has a duty to the Court that           
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