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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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