-11-
Mr. Leonard was undercompensated by $2,050,000 to $2,700,000 in
prior years. Mr. Kesner suggested an additional $296,000 should
have been paid to Mr. Leonard as retirement benefits.
We evaluate the opinions of experts in light of their
demonstrated qualifications and when considered with the other
evidence in the record. Anderson v. Commissioner, 250 F.2d 242,
249 (5th Cir. 1957), affg. in part and remanding in part T.C. Memo.
1956-178. We have broad discretion to evaluate "'the overall
cogency of each expert's analysis.'" Sammons v. Commissioner, 838
F.2d 330, 334 (9th Cir. 1988) (quoting Ebben v. Commissioner, 783
F.2d 906, 909 (9th Cir. 1986), affg. in part and revg. in part T.C.
Memo. 1983-200), affg. in part and revg. in part T.C. Memo. 1986-
318. We may accept or reject an expert's opinion in toto, or we
may pick and choose the portions of the opinion which we decide to
adopt. 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); Parker v. Commissioner, 86 T.C. 547, 562
(1986); Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506.
Here, the experts reached conclusions which patently favored
their respective clients, and their reports were designed to
support their conclusions. Previously, we have observed that
experts may lose their usefulness and credibility when they merely
become advocates for one side. See, e.g., Buffalo Tool & Die
Manufacturing Co. v. Commissioner, 74 T.C. 441, 452 (1980). We
have not hesitated to reject expert testimony when we find that the
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