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B. The Parties’ Experts
In support of their positions, each party relies on an
expert opinion. We evaluate expert opinions in light of all the
evidence in the record and may accept or reject expert testimony,
in whole or in part, according to our own judgment. Helvering v.
Natl. Grocery Co., 304 U.S. 282, 295 (1938); Shepherd v.
Commissioner, 115 T.C. 376 (2000), affd. 283 F.3d 1258 (11th Cir.
2002); Estate of Newhouse v. Commissioner, 94 T.C. 193, 217
(1990). “The persuasiveness of an expert’s opinion depends
largely upon the disclosed facts on which it is based.” Estate
of Davis v. Commissioner, 110 T.C. 530, 538 (1998). We may be
selective in our use of any part of an expert’s opinion. Id.
1. Petitioner’s Expert
Petitioner’s expert, Robert P. Oliver (Mr. Oliver), is an
accredited appraiser who has been with Management Planning, Inc.
(MPI), since 1975 and has served as its president since 1996.
MPI has been in the business of preparing financial analyses of
closely held businesses and in evaluating securities of such
businesses since 1939. Mr. Oliver is an author and speaker on
valuation and related topics.
In his direct testimony, Mr. Oliver concluded that a 7.5-
percent minority interest discount is appropriate with respect to
the marketable securities component of the partnership interests.
With respect to the real estate component, he concluded that a
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