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to show us that their profit margins were lower than the average
margin figures reported in the Department of Commerce
publications and used here by respondent.
Petitioners' contentions concerning their profit margins for
the years in issue are founded principally upon an expert report
prepared by Peter E. Rossi, Ph.D., Professor of Marketing,
Econometrics, and Statistics at the Graduate School of Business,
University of Chicago.
Expert opinion may or may not aid the Court in determining
factual issues. See Laureys v. Commissioner, 92 T.C. 101, 129
(1989). We evaluate such opinions in light of the demonstrated
qualifications of the expert and all other pertinent and credible
evidence. Estate of Newhouse v. Commissioner, 94 T.C. 193, 217
(1990); Parker v. Commissioner, 86 T.C. 547, 561 (1986); Johnson
v. Commissioner, 85 T.C. 469, 477 (1985). We are not bound,
however, by the opinion of any expert witness when that opinion
is inconsistent with our considered judgment. Estate of Newhouse
v. Commissioner, supra at 217; Parker v. Commissioner, supra at
561. We may accept the opinion of an expert in its entirety,
Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.
441, 452 (1980), and we also may be selective in the use of any
portion thereof, Parker v. Commissioner, supra at 562.
Consequently, we take into account expert opinion testimony here
only to the extent that it aids us in arriving at petitioners'
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