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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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