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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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