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particular employee in previous years. Home Interiors & Gifts,
Inc. v. Commissioner, 73 T.C. 1142, 1156 (1980); see also Owensby
& Kritikos, Inc. v. Commissioner, 819 F.2d at 1323; Pepsi-Cola
Bottling Co. of Salina, Inc. v. Commissioner, 528 F.2d at 179;
Commercial Iron Works v. Commissioner, 166 F.2d 221, 224 (5th
Cir. 1948), affg. a Memorandum Opinion of this Court. No single
factor is determinative. Home Interiors & Gifts, Inc. v.
Commissioner, supra at 1156; see also Owensby & Kritikos, Inc. v.
Commissioner, supra at 1323; Pepsi-Cola Bottling Co. of Salina,
Inc. v. Commissioner, supra at 179.
Each party presented expert testimony in support of its
positions on reasonable compensation levels. We are not bound by
the opinion of any expert when the opinion is contrary to our own
judgment. Bausch & Lomb, Inc. v. Commissioner, 92 T.C. 525, 597
(1989), affd. 933 F.2d 1084 (2d Cir. 1991); see also Estate of
Hall v. Commissioner, 92 T.C. 312, 338 (1989); Chiu v.
Commissioner, 84 T.C. 722, 734 (1985). We may embrace or reject
expert testimony, whichever in our judgment is most appropriate.
Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938). Thus,
we are not restricted to choosing the opinion of one expert over
another but may extract relevant findings from each in drawing
our own conclusions. Estate of Hall v. Commissioner, supra at
338. Here, the experts’ usefulness is primarily in the data that
they collected and analyzed.
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