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United States, 658 F.2d 999, 1006 (5th Cir. 1981)).6 The
hypothetical willing buyer and willing seller are presumed to be
dedicated to achieving the maximum economic advantage. Estate of
Newhouse, supra at 218.
III. Expert Opinions
A. Introduction
In this case, the parties rely exclusively on expert
testimony to establish the appropriate discounts to be applied in
determining the fair market value of the transferred interests.
Of course, 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
6 Although the cited cases involved the Federal estate tax,
it is well settled that the Federal estate tax and the Federal
gift tax, being in pari materia, should be construed together.
See, e.g., Shepherd v. Commissioner, 283 F.3d 1258, 1262 n.7
(11th Cir. 2002) (citing Harris v. Commissioner, 340 U.S. 106,
107 (1950)), affg. 115 T.C. 376 (2000).
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