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We evaluate the opinions of experts in light of the
qualifications of each expert and all other evidence in the
record. Estate of Christ v. Commissioner, 480 F.2d 171, 174 (9th
Cir. 1973), affg. 54 T.C. 493 (1970); Parker v. Commissioner, 86
T.C. 547, 561 (1986). We have broad discretion to evaluate “‘the
overall cogency of each expert’s analysis.’” Sammons v.
Commissioner, 838 F.2d 330, 333 (9th Cir. 1988) (quoting Ebben v.
Commissioner, 783 F.2d 906, 909 (9th Cir. 1986), affg. in part
revg. and remanding in part T.C. Memo. 1983-200), affg. in part,
revg. in part T.C. Memo. 1986-318. We are not bound by the
opinion of an expert when that opinion is contrary to our
judgment. Orth v. Commissioner, 813 F.2d 837, 842 (7th Cir.
1987), affg. Lio v. Commissioner, 85 T.C. 56 (1985); Estate of
Kreis v. Commissioner, 227 F.2d 753, 755 (6th Cir. 1955), affg.
T.C. Memo. 1954-139. While we may accept the opinion of an
expert in its entirety, Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441, 452 (1980), we may be selective in the
use of any portion of such an opinion, Parker v. Commissioner,
supra at 562.
Both experts considered numerous factors, including the
skills and responsibilities of each Retained Executive before and
after the merger and the compensation of purportedly comparable
executives of other companies. Mr. Rosenbloom conducted an
analysis of compensation paid by petitioner to the Retained
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