Wal-Mart Stores, Inc. and Subsidiaries - Page 23

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          light of his or her qualifications and with regard to all other             
          evidence in the record.  Id.; 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.  Trans City Life Ins. Co. v.            
          Commissioner, supra at 302.  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.                                       
                The Court recognized Robert M. Zimmerman, petitioners'                
          first expert, as an expert on shrinkage in the retail industry,             
          as well as on matters of GAAP.  Mr. Zimmerman has been a                    
          certified public accountant (C.P.A.) since 1959, and he has                 
          worked for a national accounting firm for 15 years as a partner             
          and/or director, specializing in the retail industry and                    
          directing the firm's operations therein.  Mr. Zimmerman consults            
          currently in the retail industry, and he has written repeatedly             
          on the subject of retail accounting and financial control.                  
          Mr. Zimmerman holds an undergraduate degree in accounting and a             
          master's degree in taxation, both from New York University.                 
                The Court recognized petitioners' second expert,                      
          Thomas E. Doerfler, as an expert on statistics.  Dr. Doerfler has           




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