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        of his or her qualifications and with proper regard to all other              
        credible evidence in the record.  We may accept or reject an expert's         
        opinion in toto, or we may pick and choose the portions of the                
        opinion which we choose to adopt.  Helvering v. National Grocery Co.,         
        304 U.S. at 294-295; Parker v. Commissioner, 86 T.C. 547, 562 (1986);         
        see also Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506.              
             We turn to the qualifications and testimony of the four                  
        witnesses whom the Court recognized as experts for purposes of this           
        proceeding.  First, the Court recognized Mark J. Perry, Ph.D. (Dr.            
        Perry), as an expert on economics with specialized knowledge on the           
        economy of Genesee County in 1992.  Dr. Perry received a bachelor of          
        arts in finance and a master of business administration in finance in         
        1985 and 1987, respectively, and he received a master of arts in              
        economics and a Ph.D. in economics in 1991 and 1993, respectively.            
        He has taught finance and economics at the university level from 1991         
        to date, and his employment in the real estate industry consists of           
        working as a real estate broker from 1982 through 1987 in the area of         
        St. Paul, Minnesota.  He currently teaches at the Flint campus of the         
        University of Michigan as an assistant professor of economics and             
        finance, and he has been in Genesee County for approximately 1 year.          
             Dr. Perry was retained by the estate to examine the economic             
        conditions in Genesee County from 1990 through 1996, focusing on 1992         
        vis-a-vis the remaining 6 years.  Dr. Perry testified that the U.S.           
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