- 26 -
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.
We have evaluated the Marshall and Stevens appraisal report
and the letters, opinions, and analyses of Mr. Atkins and Mr.
Whitcomb, both of whom we found credible. We found that report
and those letters, opinions, and analyses to be cogent and
persuasive, and we have relied on them in making our findings
herein.
According to Mr. Atkins, at the time the lease agreement was
signed in June 1988, lessors in the Denver office market were
typically offering 6 months of free rent on 5-year leases and 12
months of free rent on 10-year leases. In the opinion of Mr.
Atkins, the 11.5-month period of zero rent provided in the lease
agreement was consistent with reasonable and acceptable practice
in the Denver office market at the time that lease agreement was
executed.16 According to Mr. Atkins, it was a reasonable and
16 Although Mr. Atkins did not identify a situation in the
Denver office market of a rent holiday being offered in a lease
under which the lessee did not occupy the leased space, he did
identify two situations in localities outside that market in
which lessees who did not occupy the leased spaced received rent
holidays and discussed, but did not identify because of con-
straints imposed on him regarding their confidentiality, certain
other situations of which he was aware in which lessees received
rent holidays and did not occupy the leased space. According to
Mr. Atkins, those situations about which he testified were
(continued...)
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