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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).
We are not persuaded that Mr. Geary’s alternative method is
superior to the replacement method, and we do not find the
replacement values used by either Mr. Ferguson or Mr. Geary to be
the best estimate in the record. Rather, we find Mr. Geiger’s
replacement cost to be the best starting point. His involvement
with the construction of JUL and his background make his estimate
the best choice to start the analysis. We then depreciate his
value as Mr. Ferguson testified he would do, had he been aware of
Mr. Geiger’s report and selected his replacement cost value.
This computation yields a fair market value for JUL of
$1,060,000.
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Last modified: May 25, 2011