-245-
have taken the additional step of recasting the court-appointed
expert’s testimony to support its position since the job of
evaluating the testimony of expert witnesses and witnesses in
general is peculiarly that of the trier of fact”). Sometimes, an
expert will help us decide a case. E.g., Booth v. Commissioner,
108 T.C. at 573; Trans City Life Ins. Co. v. Commissioner, 106
T.C. 274, 302 (1996). Other times, he or she will not. 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). Aided by our
common sense, we weigh the helpfulness and persuasiveness of an
expert’s testimony in light of his or her qualifications and with
due regard to all other credible evidence in the record.
Neonatology Associates, P.A. v. Commissioner, supra at 85. We
may embrace or reject an expert’s opinion in toto, or we may pick
and choose the portions of the opinion to adopt. Helvering v.
Natl. Grocery Co., 304 U.S. at 294-295; IT&S of Iowa, Inc. v.
Commissioner, 97 T.C. 496, 508 (1991). We are not bound by an
expert’s opinion and will reject an expert’s opinion to the
extent that it is contrary to the judgment we form on the basis
of our understanding of the record as a whole. IT&S of Iowa,
Inc. v. Commissioner, supra at 508; see also Orth v.
Commissioner, 813 F.2d at 842.
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