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seller are presumed to be dedicated to achieving the maximum
economic advantage. Id. at 218.
2. Expert Opinions
a. In General
In deciding valuation cases, courts often look to the
opinions of expert witnesses. Nonetheless, we are not bound by
the opinion of any expert witness, and we may accept or reject
expert testimony in the exercise of our sound judgment.
Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938); Estate
of Newhouse v. Commissioner, supra at 217. Although we may
largely accept the opinion of one party’s expert over that of the
other party’s expert, see Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980), we may be selective in
determining what portions of each expert’s opinion, if any, to
accept, Parker v. Commissioner, 86 T.C. 547, 562 (1986).
Finally, because valuation necessarily involves an approximation,
the figure at which we arrive need not be directly traceable to
specific testimony if it is within the range of values that may
be properly derived from consideration of all the evidence.
Estate of True v. Commissioner, T.C. Memo. 2001-167 (citing
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
affg. T.C. Memo. 1974-285).
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