- 42 - 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 accuratePage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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