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1985.” In this opinion, we decide the fair market values and
useful lives of petitioner’s favorable financing assets.
Both parties rely heavily on expert opinions and testimony
to support their respective positions concerning the values and
useful lives of the favorable financing intangible assets. “[W]e
* * * consider expert opinion testimony to the extent that it
assists us in resolving the issues presented”. IT&S of Iowa,
Inc. v. Commissioner, 97 T.C. 496, 508 (1991). We may exercise
our broad discretion to accept or reject an expert’s opinion in
its entirety. Neonatology Associates, P.A. v. Commissioner, 115
T.C. 43, 86 (2000), affd. 299 F.3d 221 (3d Cir. 2002).
Alternatively, we may selectively rely on those portions of an
expert’s opinion that we find most helpful to our decision. IT&S
of Iowa, Inc. v. Commissioner, supra at 508; Parker v.
Commissioner, 86 T.C. 547, 561 (1986). “[A]n objective reason
for * * * [rejecting an expert’s testimony] is that another
expert’s opinion is more persuasive.” Parker v. Commissioner,
supra at 562. “We are not bound * * * by the opinion of any
expert witness where such opinion is contrary to our judgment.”
IT&S of Iowa, Inc. v. Commissioner, supra at 508.
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