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petitioner, who had worked for the seller for approximately
7 years and had become familiar with the seller's business
during that period.
Based upon the above, we find that petitioners have
failed to rebut the conclusions of respondent's expert,
Mr. Meade, who allocated approximately 10 percent of the
purchase price to going-concern value and the remainder to
the client list. Accordingly, we find that, of the amount
that petitioner paid to the seller, $161,225, approximately
10 percent or $16,000 should be allocated to going-concern
value and the remainder, $145,225, should be allocated to
the client list.
Useful Life of the Client List
We find that petitioner's expert, Dr. Alexander, has
understated the useful life of the subject client list.
Similarly, we find that respondent's expert, Mr. Meade, has
overstated the useful life of the client list. We may choose
to accept the opinion of one expert in its entirety, Buffalo
Tool & Die Mfg. Co. v. Commissioner, 74 T.C. 441, 452 (1980),
or we may be selective in the use of any portion of such an
opinion, see Parker v. Commissioner, 86 T.C. 547, 562 (1986);
Estate of Bennett v. Commissioner, T.C. Memo. 1989-681, affd.
without published opinion 935 F.2d 1285 (4th Cir. 1991).
Based upon all of the facts and circumstances of this case
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