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Commissioner, T.C. Memo. 1995-255, affd. without published
opinion 91 F.3d 124 (3d Cir. 1996).
As typically occurs in a case of valuation, the parties rely
primarily on their experts' testimony and reports to support the
parties' contrary positions on the valuation issue. Expert
testimony sometimes aids the Court in determining valuation.
Other times, it does not.10 The Court is not bound by an opinion
of an expert. Aided by our common sense, we weigh the
helpfulness and persuasiveness of an expert's testimony in light
of his or her qualifications and in the context of all other
credible evidence in the record. Depending on what we believe is
appropriate under the facts and circumstances of the case, we may
reject an expert's opinion in its entirety, accept it in its
entirety, or accept only selective portions of it. Helvering v.
National Grocery Co., 304 U.S. 282, 294-295 (1938); Goldstein v.
Commissioner, 298 F.2d 562, 567 (9th Cir. 1962), affg. T.C. Memo.
1960-276; In re Williams Estate, 256 F.2d 217, 219 (9th Cir.
1958), affg. T.C. Memo. 1956-239; Seagate Technology v.
Commissioner, 102 T.C. 149, 186 (1994); Parker v. Commissioner,
86 T.C. 547, 562 (1986). The Court has previously rejected an
expert's testimony as incredible when the expert's opinion of
value was so exaggerated as to make it unrealistic. See Chiu v.
10 For example, expert testimony is not useful to the Court
when the expert is merely an advocate for the position argued by
the party. Laureys v. Commissioner, 92 T.C. 101, 129 (1989).
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