-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 has
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