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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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