Garwood Irrigation Company - Page 20

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          Scheig and Mr. Camp also valued a portion of the irrigation                 
          component that they believed might become available at a later              
          date for other, higher value uses as irrigation use declined.               
               While expert 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).               
          This Court may accept or reject the opinion of an expert in its             
          entirety, or we may be selective in the use of any portion.                 
          Estate of Davis v. Commissioner, 110 T.C. 530, 538 (1998); Parker           
          v. Commissioner, 86 T.C. 547, 562 (1986); Buffalo Tool & Die                
          Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980).  Mr.            
          Lloyd concluded that the value of the water right was $10.7                 
          million on the valuation date.  Mr. Camp concluded that the value           
          of the water right was $29,397,000, and petitioner reported this            
          value on its 1999 return.  Mr. Scheig concluded that the value of           
          the water right was $45,809,384 on the valuation date.  Mr.                 
          Scheig’s valuation represents a significant departure from                  
          respondent’s position in the notice of deficiency, in which                 
          respondent stated that petitioner’s assets were worth $76,609,000           

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