-80-
petitioner acquired a trade or business,50 paid a premium, and
acquired goodwill. The parties presented expert witnesses to value
the lease portfolio and thereby determine whether petitioner paid
for any goodwill or going-concern value when it purchased FIA's
assets.
G. Expert Witnesses
As the trier of fact, we must weigh the evidence presented by
the experts in light of their demonstrated qualifications in
addition to all other credible evidence. Estate of Christ v.
Commissioner, 480 F.2d 171, 174 (9th Cir. 1973), affg. 54 T.C. 493
(1970). However, we are not bound by the opinion of any expert
witness when that opinion is contrary to our judgment. Estate of
Kreis v. Commissioner, 227 F.2d 753, 755 (6th Cir. 1955), affg.
T.C. Memo. 1954-139; Chiu v. Commissioner, 84 T.C. 722, 734 (1985).
We may accept or reject expert testimony as we find appropriate in
our best judgment. 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 claims that the value of the lease portfolio is
$134,383,364, while respondent contends that the value is
50 Respondent points to the fact that in its Application
to the Board of Governors of the Federal Reserve System,
petitioner sought approval "to acquire substantially all of the
assets and assume substantially all of the liabilities (to
unrelated parties) of a going concern". (Emphasis added.)
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