- 43 -
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);
Parker v. Commissioner, 86 T.C. 547, 561 (1986). We are not
bound by an expert’s opinion, especially when it is contrary to
our own judgment. Orth v. Commissioner, 813 F.2d 837, 842
(7th Cir. 1987), affg. Lio v. Commissioner, 85 T.C. 56 (1985);
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
affg. T.C. Memo. 1974-285; Estate of Kreis v. Commissioner,
227 F.2d 753, 755 (6th Cir. 1955), affg. T.C. Memo. 1954-139.
If we believe it is appropriate to do so, we may adopt an
expert’s opinion in its entirety, or we may reject it in its
entirety. Helvering v. National Grocery Co., 304 U.S. 282,
294-295 (1938); see Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980). We may also choose to
adopt only parts of an expert’s opinion. Parker v. Commissioner,
supra at 562.
We find the opinion of Ms. Wallace to be most helpful in
resolving the issues presented herein, and we rely heavily on it
in making our findings and reaching our conclusions. Ms.
Wallace’s testimony and reasoning were more clear, coherent, and
persuasive than those of her counterparts; namely, Messrs. Sayre,
Turnquist, and Beardsley. We are unpersuaded by, and generally
do not rely on, the opinions of Messrs. Sayre, Turnquist, and
Beardsley in making our findings or in reaching our conclusions.
We find the opinions of Messrs. Sayre and Turnquist to be
inconsistent and problematic, and we generally find that their
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