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on voir dire, cross-examination, redirect examination, and
recross-examination.
We evaluate the opinions of experts in light of the qualifi-
cations of each expert and all other evidence in the record. See
Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th Cir.
1973), affg. 54 T.C. 493 (1970); IT&S of Iowa, Inc. v. Commis-
sioner, 97 T.C. 496, 508 (1991). 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 on another issue T.C.
Memo. 1986-318). We are not bound by the formulae and opinions
proffered by an expert, especially when they are contrary to our
own judgment. Orth v. Commissioner, 813 F.2d 837, 842 (7th Cir.
1987), affg. Lio v. Commissioner, 85 T.C. 56 (1985); Silverman v.
Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), affg. T.C. Memo.
1974-285. Instead, we may reach a decision based on our own
analysis of all the evidence in the record. Silverman v. Commis-
sioner, supra at 933. The persuasiveness of an expert’s opinion
depends largely upon the disclosed facts on which it is based.
Tripp v. Commissioner, 337 F.2d 432, 434 (7th Cir. 1964), affg.
T.C. Memo. 1963-244. While we may accept the opinion of an
expert in its entirety, see Buffalo Tool & Die Manufacturing Co.
v. Commissioner, 74 T.C. 441, 452 (1980), we may be selective in
23(...continued)
prepared the addendum to his expert report on the day before the
first day of the further trial in this case.
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