Alpha Medical, Inc., f.k.a. Alpha Medical Management, Inc. - Page 23

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          opposed to the efforts and business acumen of the employees.                
          General economic conditions may affect a business' performance              
          and indicate the extent (if any) of the employees' effect on the            
          company.  Mayson Manufacturing Co. v. Commissioner, 178 F.2d at             
          119-120.  Adverse economic conditions, for example, tend to show            
          that an employee's skill was important to a company that grew               
          during the bad years.                                                       
               At trial, petitioner presented expert witness testimony as             
          to the reasonableness of Rogers' compensation.  Expert witness              
          testimony is appropriate to help 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 Tech., Inc. & Consol. Subs. v. Commissioner, 102            
          T.C. 149, 186 (1994).                                                       
               Petitioner's expert, Mr. James V. Hughes (Hughes), is an               
          expert on compensation with Arthur Anderson & Co.  Hughes                   
          testified at trial and submitted a report that he coauthored with           
          Bruce K. Benesh (Benesh).  Benesh did not testify at trial.                 



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