- 147 - 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.Page: Previous 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 Next
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