- 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 theirPage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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