Zinovy Brodsky - Page 132




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          the use of any portion of such an opinion, see Parker v. Commis-            
          sioner, 86 T.C. 547, 562 (1986).  Furthermore, we may reject the            
          opinion of an expert in its entirety.  Palmer v. Commissioner,              
          523 F.2d 1308, 1310 (8th Cir. 1975), affg. 62 T.C. 684 (1974);              
          Parker v. Commissioner, supra at 562-565.                                   
               In preparing his expert report and the addendum to that                
          report, Mr. Jordan had no personal knowledge about any facts with           
          respect to:  (1) The items reported in (a) the joint returns of             
          petitioner and Ms. Brodsky for the years at issue and (b) MZ                
          Trading’s Form 1065 for 1993; (2) the accounts of (a) petitioner            
          and/or Ms. Brodsky during the years at issue and (b) MZ Trading             
          during 1993, including any deposits into and withdrawals from               
          those accounts; and (3)(a) the personal dealings and business               
          transactions of petitioner and/or Ms. Brodsky during the years at           
          issue and (b) the transactions of MZ Trading during 1993.  During           
          his testimony, Mr. Jordan acknowledged that he accepted as facts            
          certain representations that petitioner, whom we did not find to            
          be credible, had made to him (petitioner’s representations) and             
          accepted as accurate certain documents, which we did not find to            
          be credible, that petitioner had provided to him (petitioner’s              
          documents) and that he based his analysis, opinions, and conclu-            
          sions upon those representations and those documents.24                     
          Petiioner did not provide Mr. Jordan with general ledgers, books            
          of account, receipts, or other business records of petitioner,              

               24We note that certain of petitioner’s representations and             
          petitioner’s documents on which Mr. Jordan relied are not part of           
          the record in this case.                                                    




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