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of Consulting Actuaries since 1987. Various courts, including
this one, have previously recognized Mr. DeWeese as an expert on
subjects similar to those relevant herein, and he has repeatedly
testified as an expert on those subjects, including twice in this
Court. See Neonatology Associates, P.A. v. Commissioner, supra
at 85-86; Booth v. Commissioner, 108 T.C. 524, 573 (1997).
The Court has broad discretion to evaluate the cogency of an
expert’s analysis. See Neonatology Associates, P.A. v.
Commissioner, supra at 85. Sometimes, an expert will help us
decide a case. See, e.g., id.; Booth v. Commissioner, supra at
573; Trans City Life Ins. Co. v. Commissioner, 106 T.C. 274, 302
(1996). Other times, he or she will not. See, e.g., Estate of
Scanlan v. Commissioner, T.C. Memo. 1996-331, affd. without
published opinion 116 F.3d 1476 (5th Cir. 1997); Mandelbaum v.
Commissioner, T.C. Memo. 1995-255, affd. without published
opinion 91 F.3d 124 (3d Cir. 1996). Aided by our common sense
and our perception of the expert during his or her testimony, we
weigh the helpfulness and persuasiveness of an expert’s testimony
in the light of his or her qualifications and with due regard to
all other credible evidence in the record. See Neonatology
Associates, P.A. v. Commissioner, supra at 84-85. We may embrace
or reject an expert’s opinion in toto, or we may pick and choose
the portions of the opinion to adopt. See Helvering v. Natl.
Grocery Co., 304 U.S. 282, 294-295 (1938); IT&S of Iowa, Inc. v.
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