Herbert V. Kohler, Jr., et al. - Page 27

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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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