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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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