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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).
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