-21- Elliotts, Inc. v. Commissioner, 716 F.2d at 1246; see sec. 1.162- 7(b)(3), Income Tax Regs. Both parties rely on expert opinions for purposes of determining external comparison. As the trier of fact, we must weigh the evidence presented by the experts in light of their demonstrated qualifications in addition to all other credible evidence. Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir. 1973), affg. 54 T.C. 493 (1970); IT&S of Iowa, Inc. v. Commissioner, 97 T.C. 496, 508 (1991). However, we are not bound by any expert opinion that is contrary to our judgment. Estate of Kreis v. Commissioner, 227 F.2d 753, 755 (6th Cir. 1955), affg. T.C. Memo. 1954-139; Estate of Hall v. Commissioner, 92 T.C. 312, 338 (1989); Chiu v. Commissioner, 84 T.C. 722, 734 (1985). We may be selective in deciding to accept or reject expert opinion in its entirety, or accept selective portions of it. Helvering v. National Grocery Co., 304 U.S. 282, 294-295 (1938); Orth v. Commissioner, 813 F.2d 837, 842 (7th Cir. 1987), affg. Lio v. Commissioner, 85 T.C. 56 (1985); Seagate Tech., Inc. v. Commissioner, 102 T.C. 149, 186 (1994). We may reach a decision based on our own analysis of all the evidence in the record. Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo. 1974-285. Respondent’s expert, Emmett James Brennan III, prepared a report and testified as to compensation in corporate pay practices. Mr. Brennan is president of a compensation consulting firm who hasPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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