- 61 -
record. Silverman v. Commissioner, supra at 933. The persua-
siveness of an expert's opinion depends largely upon the dis-
closed facts on which it is based. See Tripp v. Commissioner,
337 F.2d 432, 434 (7th Cir. 1964), affg. T.C. Memo. 1963-244.
While we may accept the opinion of an expert in its entirety,
Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.
441, 452 (1980), we may be selective in the use of any portion of
such an opinion. Parker v. Commissioner, supra at 562. We also
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.
Mr. Balotti's Reports
We found the focus of Mr. Balotti's reports to be in large
part misdirected. Mr. Balotti's reports focus primarily on
whether the director class voting requirement, the stockholder
class voting requirement, the mandatory dividend provision, and
the objectionable action provision prevented the board of Alumax
from managing its business and affairs. He concludes that those
requirements and provisions did not "significantly alter or
impair" the power of the Alumax board to manage the business and
affairs of Alumax or the exercise of such power. However, it is
respondent's position that the director class voting requirement
caused the Alumax board's power with respect to the restricted
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