Square D Company and Subsidiaries - Page 96

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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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