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1986-318; Estate of True v. Commissioner, T.C. Memo. 2001-167.
Although expert testimony usually helps the Court determine
values, sometimes it does not, particularly when the expert is
merely an advocate for the position argued by one of the parties.
See, e.g., Estate of Halas v. Commissioner, 94 T.C. 570, 577
(1990); Laureys v. Commissioner, 92 T.C. 101, 129 (1989); Estate
of True v. Commissioner, supra. We have rejected expert opinions
based on conclusions that are unexplained or contrary to the
evidence. See Knight v. Commissioner, 115 T.C. 506 (2000); Rose
v. Commissioner, 88 T.C. 386, 401 (1987), affd. 868 F.2d 851 (6th
Cir. 1989). Testimony that is inherently improbable or
manifestly unreasonable may be rejected, even though no
contradictory evidence is offered. Quock Ting v. United States,
140 U.S. 417 (1891).
Petitioners claim the value of the Atmore residence
decreased by more than 30 percent ($300,000 decrease in value of
$989,158 house) as a result of the crack or cracks in the tile
floors and more than 21 percent ($214,168 decrease in value of
$989,158 house) as a result of damage to the exterior brick and
the need to install the vinyl siding. Petitioners did not
explain the methodology or the factors used to make their
valuations. It is improbable that the value of the Atmore
residence would drop by more than 30 percent simply because of a
crack or cracks in the tile floors with no evidence of damage to
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