- 62 -
affg. T.C. Memo. 1954-139. Instead, we may reach a decision
based on our own analysis of all the evidence in the record.
Silverman v. Commissioner, supra at 933. The persuasiveness of
an expert's opinion depends largely upon the disclosed facts on
which it is based. See Tripp v. Commissioner, 337 F.2d 432, 434
(7th Cir. 1964), affg. T.C. Memo. 1963-244. While we may accept
the opinion of an expert in its entirety, Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980), we
may be selective in the use of any portion of such an opinion.
Parker v. Commissioner, supra at 562. Furthermore, we may reject
the opinion of an expert witness in its entirety. See Palmer v.
Commissioner, 523 F.2d 1308, 1310 (8th Cir. 1975), affg. 62 T.C.
684 (1974); Parker v. Commissioner, supra at 562-565.
Petitioners rely on the opinions of Douglas E. Nieh (Mr.
Nieh) who was employed by Polaroid Corporation (Polaroid) in its
sunglass business from 1956 through 1988. His opinions were
based on his experience in the sunglass industry. We found Mr.
Nieh's opinions to be helpful in resolving the issues presented,
and we rely on them to the extent discussed below in making our
findings and reaching our conclusions herein.
Although respondent does not rely on an expert from the
sunglass industry, she does rely on the opinions of Dr. Cohen, a
licensed optician and an associate professor of Ophthalmic Dis-
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