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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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