- 38 -                                         
          opinion of one expert over another, but may extract relevant                
          findings from each in reaching our own conclusions.  Chiu v.                
          Commissioner, 84 T.C. 722, 734 (1985).                                      
               We find significant errors in the approach of each of the              
          parties' experts in determining a reasonable royalty rate.  For             
          example, Mr. Parker proceeded under the assumption that a                   
          prospective licensee would have no doubts as to the validity,               
          enforceability, and ownership of the Amoco patents.  He made no             
          attempt to quantify the differences between the licenses of the Sea         
          Bulk patents and the license of the Amoco patents.                          
               Mr. Thomas relied on the license of the Amoco patents by               
          Powertex to Insta-Bulk in settlement of their litigation as a               
          sufficiently similar transaction involving an unrelated party.  As          
          we noted above, however, the fact that this license was granted in          
          settlement of litigation prevented it from being a sufficiently             
          similar transaction for purposes of section 1.482-2(d)(2)(ii),              
          Income Tax Regs.  Additionally, we are puzzled as to his decision to        
          examine the factors found in Georgia-Pacific Corp. v. U.S. Plywood          
          Corp., 318 F. Supp. at 1120, instead of those enumerated in section         
          1.482-2(d)(2)(iii), Income Tax Regs.  Although some of the Georgia-         
          Pacific Corp. factors are similar to those listed in the regulation,        
          several are not.  For example, the Georgia-Pacific Corp. factors            
          include the derivative effect of selling the patented product in            
          promoting sales of other products of the licensee and opinions from         
          expert witnesses, factors which are not included in the regulation.         
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