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the Court understand an area requiring specialized training,
knowledge, or judgment. Fed. R. Evid. 702; Snyder v.
Commissioner, 93 T.C. 529, 534 (1989). The Court, however, is
not bound by an expert's opinion. We weigh an expert's testimony
in light of his or her qualifications, and with respect to all
credible evidence in the record. Depending on what we believe is
appropriate under the facts and circumstances of the case, we may
either reject an expert's opinion in its entirety, accept it in
its entirety, or accept selective portions of it. Helvering v.
National Grocery Co., 304 U.S. 282, 294-295 (1938); Seagate
Technology, Inc. & consol. Subs. v. Commissioner, 102 T.C. 149,
186 (1994); Parker v. Commissioner, 86 T.C. 547, 562 (1986).
Petitioner's expert is Paul R. Dorf, managing director of
Compensation Resources, Inc., of Upper Saddle River, New Jersey.
Respondent's expert is E. James Brennan III, president of
Brennan, Thomsen Associates, Inc., of Chesterfield, Missouri.
Mr. Brennan is no stranger to this Court, having testified before
us on no fewer than 13 prior occasions. See Alondra Indus. Ltd.
v. Commissioner, T.C. Memo. 1996-32; Guy Schoenecker, Inc. v.
Commissioner, T.C. Memo. 1995-539; Mad Auto Wrecking, Inc. v.
Commissioner, T.C. Memo. 1995-153, and the cases cited therein.
We are not persuaded by either of the experts. Mr. Dorf's
testimony was unconvincing because it did not directly address
the factor at hand; i.e., the prevailing rates of compensation
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