- 73 -
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.
Page: Previous 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 NextLast modified: May 25, 2011