Estate of Nora Kolczynski, Deceased, Matthew Hoffmeier, Executor - Page 9

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               Respondent presented the testimony of Robert O’Rear (Mr.               
          O’Rear).  Mr. O’Rear has a B.S. in forestry and has taken at                
          least two valuation classes.  His 30 years of work experience               
          include appraising timber, timberland, cropland, and forest                 
          plantations.  He prepared an expert report in accordance with               
          Rule 143(f), and respondent identified Mr. O’Rear as a witness in           
          his pretrial memorandum.  Mr. O’Rear’s professional training and            
          work experience qualify him as an expert to value DP for estate             
          tax purposes.                                                               
               Each party urges us to reject the other party’s expert’s               
          opinions.  We may, however, accept or reject the opinion of an              
          expert in its entirety, or we may be selective in the use of any            
          portion thereof.  Estate of Davis v. Commissioner, supra at 538;            
          Parker v. Commissioner, 86 T.C. 547, 562 (1986); Buffalo Tool &             
          Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980).             
          Stated differently, we decide, as the trier of fact, the weight             
          afforded any witness’s testimony, and we are not compelled to               
          accept any testimony even if it is uncontradicted.  McGraw v.               
          Commissioner, 384 F.3d 965, 972 (8th Cir. 2004), affg. Butler v.            
          Commissioner, T.C. Memo. 2002-314; Paul E. Kummer Realty Co. v.             
          Commissioner, 511 F.2d 313, 315 (8th Cir. 1975), affg. T.C. Memo.           
          1974-44.                                                                    









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