Estate of Nathaniel M. Leichter, Deceased, Steven Leichter, Co-Special Administrator - Page 13




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          court.  Moreover, respondent’s expert arrived at a value that was           
          a mere $60,000 or 3 percent more than reported on the estate tax            
          return.                                                                     
               In reaching our holding on the fair market value of Harlee,            
          we consider the expert witnesses’ reports.  It is within this               
          Court’s discretion to evaluate the cogency of their conclusions             
          and opinions.  Sammons v. Commissioner, 838 F.2d 330, 333 (9th              
          Cir. 1988), affg. on this point and revg. on another ground T.C.            
          Memo. 1986-318.  This Court evaluates opinions of experts in                
          light of each expert’s demonstrated qualifications and the                  
          evidence in the record.  Estate of Davis v. Commissioner, 110               
          T.C. 530, 538 (1998) (and cases cited therein).  Accordingly,               
          this Court may accept or reject all or part of an expert’s                  
          opinion.  Id.                                                               
               For purposes of supporting a substantially lower value than            
          reported, the estate offered two experts, one valuing Harlee at             
          $863,000 and the other at $400,000.  Respondent offered one                 
          expert, who valued Harlee at $2,150,000.  While neither party               
          offered Mr. Sherman, who valued Harlee at $2,091,750 for purposes           
          of the estate tax return, the Sherman Appraisal itself is part of           
          the record.                                                                 
               Mr. Burdette Garvin was hired by the estate for litigation             
          purposes and opined that the value of Harlee was $863,000 as of             
          October 23, 1995.  Although Mr. Garvin seemed to have working               







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