Estate of Paul Mitchell, Deceased - Page 23




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          exceeds his duty to his client; the expert is obligated to present          
          data, analysis, and opinion with detached neutrality and without            
          bias.  Estate of Halas v. Commissioner, 94 T.C. 570, 577-578                
          (1990).  In the context of valuation cases, experts lose their              
          usefulness (and credibility) when they merely become advocates for          
          the position argued by a party.  Laureys v. Commissioner, supra at          
          129; Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.          
          441, 452 (1980).  When an expert displays an unyielding allegiance          
          to the party who is paying his or her bill, we generally will               
          disregard that testimony as untrustworthy.  Estate of Halas v.              
          Commissioner, supra; Laureys v. Commissioner, supra.                        
               Where experts offer divergent estimates of fair market value,          
          we decide what weight to give these estimates by examining the              
          factors they used in arriving at their conclusions.  Casey v.               
          Commissioner, 38 T.C. 357, 381 (1962).  We have broad discretion in         
          selecting valuation methods, Estate of O’Connell v. Commissioner,           
          640 F.2d 249, 251 (9th Cir. 1981), affg. on this issue and revg. in         
          part T.C. Memo. 1978-191, and the weight to be given the facts in           
          reaching our conclusion, Colonial Fabrics, Inc. v. Commissioner,            
          202 F.2d 105, 107 (2d Cir. 1953), affg. a Memorandum Opinion of             
          this Court.                                                                 
               We have considered all of the testimony before us, as well as          
          the expert witness reports, and have weighed all other relevant             








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