Ronald P. Barranti and Stephanya M. Barranti - Page 10

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          testimony is appropriate to help the Court understand an area               
          requiring specialized training, knowledge, or judgment.  Fed. R.            
          Evid. 702; Snyder v. Commissioner, 93 T.C. 529, 534 (1989).  The            
          Court, however, is not bound by an expert's opinion.  We weigh an           
          expert's testimony in light of his or her qualifications and with           
          respect to all credible evidence in the record.  Depending on               
          what we believe is appropriate under the facts and circumstances            
          of the case, we may either reject an expert's opinion in its                
          entirety, accept it in its entirety, or accept selective portions           
          of it.  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).                                                       
               Petitioners' expert, Lori L. Horn (Horn), is a certified               
          residential real estate appraiser in the State of California, and           
          has been an appraiser for 15 years.  Horn testified at trial and            
          submitted a written report in which she concluded that the fair             
          market rental value of petitioner's property during the year at             
          issue was $850 per month.  In concluding that $500 per month was            
          the appropriate cash rent amount, Horn took the sum of the values           
          of Murray's repairs and maintenance work divided by 14 months               
          (May 1992 through June 1993), and subtracted that amount from               
          $850.                                                                       
               We do not find Horn's opinion persuasive.  For the evidence            
          of comparable rents to be accorded any weight, it must be shown             





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