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facts.” United States v. Cartwright, 411 U.S. 545, 551 (1973);
sec. 20.2031-1(b), Estate Tax Regs. The willing buyer and the
willing seller are hypothetical persons, instead of specific
individuals and entities, and the characteristics of these
imaginary persons are not necessarily the same as the personal
characteristics of the actual seller or a particular buyer. See
Estate of Bright v. United States, 658 F.2d 999, 1005-1006 (5th
Cir. 1981).
Real estate valuation is a question of fact to be resolved
on the basis of the entire record. See Ahmanson Found. v. United
States, 674 F.2d 761, 769 (9th Cir. 1981); Estate of Fawcett v.
Commissioner, 64 T.C. 889, 898 (1975). The valuation must
reflect the highest and best use to which the property could be
put on the relevant valuation date. Symington v. Commissioner,
87 T.C. 892, 896 (1986).
Valuation is an inexact process. See Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980). As
the trier of fact, we may use experts to assist us in deciding
upon value, but we are not bound by those experts’ views or
opinions. See Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976), affg. T.C. Memo. 1974-285; Chiu v. Commissioner, 84
T.C. 722, 734 (1985). One expert may be persuasive on a
particular element of valuation, and another expert may be
persuasive on another element. See Parker v. Commissioner, 86
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