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to evaluate the cogency of their conclusions and opinions.
Sammons v. Commissioner, 838 F.2d 330, 333 (9th Cir. 1988), affg.
on this point and revg. on another ground T.C. Memo. 1986-318.
This Court evaluates opinions of experts in light of each
expert’s demonstrated qualifications and the evidence in the
record. Estate of Davis v. Commissioner, 110 T.C. 530, 538
(1998) (and cases cited thereat). Accordingly, this Court may
accept or reject all or parts of an expert’s opinion. Id.
First, we consider petitioner’s expert’s (Mr. Knoblick’s)
approach to valuing the customer accounts acquired from Rose. He
began by comparing Rose’s designated categories of customer
accounts with those petitioner used and determined, with one
exception, that both companies used similar categories to
characterize their customers. Mr. Knoblick next analyzed Rose’s
annual (12-month) income for each of its categories of customer
accounts for the period ended March 31, 1989.
Mr. Knoblick then determined the useful lives of the
acquired accounts on the basis of petitioner’s experiences with
similar discount brokerage customer accounts. He used
petitioner’s data because Rose’s data was not available and, more
significantly, because petitioner’s data would be a more accurate
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