Shigenori Kudo and Motomi Kudo, et al. - Page 76

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          to total sales show that the restaurants could not have had any             
          unreported sales for the years in issue.  The percentage markup             
          figures upon which Shimmon relied represent an average of all               
          grades of restaurants.  Shimmon considered the restaurants in               
          question to be medium-grade restaurants.                                    
               Respondent contends that petitioners have failed to                    
          establish that respondent's determination was erroneous.                    
          Respondent maintains that the source of the Takaos' unexplained             
          cash deposits was unreported gross receipts from Toraya.                    
          Respondent argues that the Court should give little weight to               
          Shimmon's testimony, because his conclusions were based on                  
          computerized records that are not in the record; thus, his                  
          calculations cannot be verified.                                            
               We weigh expert testimony in light of the expert's                     
          qualifications as well as all the other credible evidence in the            
          record.  Estate of Newhouse v. Commissioner, 94 T.C. 193, 217               
          (1990).  We are not bound by the opinion of any expert witness,             
          and we will accept or reject that expert testimony when, in our             
          best judgment based on the record, it is appropriate to do so.              
          Id.; Chiu v. Commissioner, 84 T.C. 722, 734 (1985).  While we may           
          choose to accept the opinion of one expert in its entirety,                 
          Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C.               
          441, 452 (1980), we may also be selective in the use of any                 
          portion of that opinion, Parker v. Commissioner, 86 T.C. 547, 562           
          (1986).                                                                     




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