Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 47

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          buyer and a willing seller, neither being under any compulsion to           
          buy or to sell and both having reasonable knowledge of relevant             
          facts".  See, e.g., United States v. Cartwright, 411 U.S. 546,              
          551 (1973); sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2501-1,            
          Gift Tax Regs.                                                              
               The determination of fair market value is a question of fact           
          to be resolved from all the evidence.  Estate of Ford v.                    
          Commissioner, 53 F.3d 924, 926 (8th Cir. 1995), affg. T.C. Memo.            
          1993-580.  Valuation is necessarily an approximation and is, in             
          great part, a question of judgment rather than math or formula.             
          Hamm v. Commissioner, 325 F.2d 934, 940 (8th Cir. 1963), affg.              
          T.C. Memo. 1961-347.  As the estate has not demonstrated that               
          section 7491(a) applies, the estate bears the burden of proving             
          that the values determined by respondent are incorrect.  Rule               
          142(a).                                                                     
          Evaluation of Expert Testimony                                              
               At trial respondent offered the testimony of Agent                     
          Puntenney, purportedly as a fact witness, to explain the                    
          methodology he employed in reaching the values determined for               
          decedent's farm land in the notice of deficiency.  The estate               
          objected on the grounds that such testimony necessarily involved            
          the presentation of expert opinion, which was impermissible given           
          that respondent had neither established Agent Puntenney's                   
          qualifications as an expert nor offered an expert report in                 






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