The Charles Schwab Corporation and Subsidiaries - Page 42

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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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