-27- experts’ value conclusions with respect to the estate’s stock on the alternate valuation date differed by more than $100 million, no nominal amount. When considering expert testimony, a court is not required to follow the opinion of any expert if it is contrary to the court’s judgment. Id. (citing Helvering v. Natl. Grocery Co., 304 U.S. at 295 and Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo. 1974-285). A court may adopt or reject expert testimony and will reject expert testimony where the witness’ opinion of value is so exaggerated that the testimony is incredible. Estate of Hall v. Commissioner, 92 T.C. 312, 338 (1989); Chiu v. Commissioner, 84 T.C. 722, 734-735 (1985); Estate of Deputy v. Commissioner, supra. We are not obligated to pay any regard to an expert opinion that lacks credibility. Estate of Hall v. Commissioner, supra; Chiu v. Commissioner, supra; Estate of Deputy v. Commissioner, supra. We may find evidence of valuation provided by one of the parties to be much more credible than that of the other party, so that our findings result in a significant victory for one side, rather than a compromise between the two. See Buffalo Tool & Die Mfg. Co. v. Commissioner, 74 T.C. 441, 452 (1980). 8(...continued) death than on the alternate valuation date. See sec. 2032(c).Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011