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reasonable, being apparently limited to the places where BDC
already had customers.
(i) The seller's intention to remain in the same geographic
area. Mr. Langdon had lived in Bemidji all his life and intended
to remain there. He was still living there at time of trial.
Respondent's Expert
Respondent submitted the expert witness report and testimony
of Nhoth Chouravong to establish the value of Mr. Langdon's
covenant not to compete.
Expert testimony may help the Court understand an area
requiring specialized training, knowledge, or judgment. Snyder
v. Commissioner, 93 T.C. 529, 534 (1989). We may be selective in
deciding what part of an expert's testimony we accept. Helvering
v. Natl. Grocery Co., 304 U.S. 282, 295 (1938); Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285; Parker v. Commissioner, 86 T.C. 547, 561 (1986).
Mr. Chouravong is employed as a general and industrial
engineer with the IRS and has valued closely held businesses and
various types of tangible (real and personal) and intangible
property. He has a B.S. degree in industrial engineering and an
M.B.A. with a major in finance.
However, only 20 percent of Mr. Chouravong's actual job
duties involves doing valuations. He is not certified by any
professional organization. He has never valued a beer
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