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opinions may assist in evaluating a claim, we are not bound by
these opinions and may reach a decision based on our own analysis
of all the evidence in the record. Helvering v. Natl. Grocery
Co., 304 U.S. 282, 295 (1938); Estate of Newhouse v.
Commissioner, 94 T.C. 193, 217 (1990). Where experts offer
conflicting estimates of fair market value, we must weigh each
estimate by analyzing the factors they used to arrive at their
conclusions. Casey v. Commissioner, 38 T.C. 357, 381 (1962). We
may accept the opinion of an expert in its entirety, or we may be
selective in the use of any portion. Parker v. Commissioner, 86
T.C. 547, 562 (1986); Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980). Mr. Perdue’s report
concluded that the value of the Victorville property was $8.5
million ($2.10 per square foot) on the valuation date. Mr.
Thompson’s report concluded that the value of the Victorville
property was $4.45 million ($1.10 per square foot) on the
valuation date.
The Court of Appeals for the Ninth Circuit has held that the
burden of persuasion may be shifted from the taxpayer to the
Commissioner when the Commissioner’s determination is shown to be
invalid by his own expert. See, e.g., Estate of Mitchell v.
Commissioner, 250 F.3d 696, 702 (9th Cir. 2001), affg. in part,
vacating in part and remanding T.C. Memo. 1997-461. At trial,
respondent’s expert placed a value of $8.5 million on the
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