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experts on their opinions on the question of value. In that
regard, we note that the parties’ experts’ reports constitute
opinion testimony, and such testimony is not fact for purposes of
our ultimate findings. Accordingly, there exists no dispute
about the underlying facts, and, ultimately, we are asked to
decide the amount of reduction for built-in capital gain tax
liability and the discounts for lack of marketability and
control. In the setting of this case, those questions will be
resolved on the basis of essentially agreed facts along with any
assistance we may find helpful in the parties’ experts’ opinions,
not on the basis of which party bears the burden of proof.
In such circumstances the question of who has the burden of
proof or who should go forward with the evidence is irrelevant.
See, e.g., Estate of Hillgren v. Commissioner, T.C. Memo. 2004-
46; Estate of Green v. Commissioner, T.C. Memo. 2003-348; Estate
of Deputy v. Commissioner, supra. Therefore, there is no need to
decide whether the estate met the “credible evidence”
requirement.
B. CCC’s Value on March 4, 1999
The controversy presented for our decision concerns the
value of a 6.44-percent interest in CCC, a corporation closely
held by the Jelke family. For estate tax purposes, property
includable in decedent’s gross estate is generally valued as of
the date of death. See sec. 2001. The fair market value is
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