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witness was Charles DeWeese, F.S.A., M.A.A.A. (Mr. DeWeese). Mr.
DeWeese is an independent consulting actuary, and we recognized
him as an expert on, among other things, the difference between
group term insurance and universal life insurance. Mr. DeWeese
generally testified that the C-group term policy and the C-group
conversion UL policy were one insurance product; i.e., both
policies were parts of a single life insurance product.
We have broad discretion to evaluate the cogency of an
expert’s analysis. Sometimes, an expert will help us decide a
case. See, e.g., Booth v. Commissioner, supra at 573; Trans City
Life Ins. Co. v. Commissioner, 106 T.C. 274, 302 (1996); see also
M.I.C. Ltd. v. Commissioner, T.C. Memo. 1997-96; Proios v.
Commissioner, T.C. Memo. 1994-442. Other times, he or she will
not. See, e.g., Estate of Scanlan v. Commissioner, T.C. Memo.
1996-331, affd. without published opinion 116 F.3d 1476 (5th Cir.
1997); Mandelbaum v. Commissioner, T.C. Memo. 1995-255, affd.
without published opinion 91 F.3d 124 (3d Cir. 1996). We weigh
an expert’s testimony in light of his or her qualifications and
with due regard to all other credible evidence in the record.
See Estate of Kaufman v. Commissioner, T.C. Memo. 1999-119. We
may embrace or reject an expert’s opinion in toto, or we may pick
and choose the portions of the opinion we choose to adopt. See
Helvering v. National Grocery Co., 304 U.S. 282, 294-295 (1938);
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976),
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