- 8 -
(9th Cir. 1986), affg. in part and reversing in part T.C. Memo.
1983-200). We are not bound by the formulae and opinions prof-
fered by expert witnesses, especially when they are contrary to
our judgment. Silverman v. Commissioner, 538 F.2d 927, 933 (2d
Cir. 1976), affg. T.C. Memo. 1974-285; IT&S of Iowa, Inc. v.
Commissioner, 97 T.C. 496, 508 (1991). Instead, we may reach a
determination of value based on our own examination of the
evidence in the record. Lukens v. Commissioner, 945 F.2d 92, 96
(5th Cir. 1991), affg. Ames v. Commissioner, T.C. Memo. 1990-87
(citing Silverman v. Commissioner, supra). The persuasiveness of
an expert's opinion depends largely upon the disclosed facts on
which it is based. See Tripp v. Commissioner, 337 F.2d 432, 434
(7th Cir. 1964), affg. T.C. Memo. 1963-244. Where experts offer
divergent estimates of fair market value, we shall decide what
weight to give those estimates by examining the factors used by
those experts to arrive at their conclusions. Casey v. Commis-
sioner, 38 T.C. 357, 381 (1962). 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 part of such an opinion, Parker v. Commis-
sioner, supra at 562. We also may reject the opinion of an
expert witness in its entirety. Palmer v. Commissioner, 523 F.2d
1308, 1310 (8th Cir. 1975), affg. 62 T.C. 684 (1974); Parker v.
Commissioner, supra at 562-565.
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