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Commissioner, 97 T.C. 496, 508 (1991). We are not bound by an
expert’s opinion and will reject an expert’s opinion to the
extent that it is contrary to the judgment we form on the basis
of our understanding of the record as a whole. See IT&S of Iowa,
Inc. v. Commissioner, supra at 508.
In making our findings of fact and reaching our decisions
herein, we have given little weight to the testimony of Mr.
Frank. Although the Court recognized Mr. Frank as an expert on
the stated subjects, we were and remain troubled that Mr. Frank
has a longstanding and continuing working and personal
relationship with Mr. Carpenter and other entities and persons
with financial and/or other direct interests in the resolution of
these cases. See Neonatology Associates, P.A. v. Commissioner,
115 T.C. at 86 (stating that “An expert witness loses his or her
impartiality when he or she is too closely connected with one of
the parties” and holding that such an expert is of limited value
to the Court). In fact, during trial, we were forced to admonish
Mr. Frank that he should not be improperly communicating with one
or more of the just-referenced persons and petitioners’ counsel.
In addition to that stated relationship, we also on the basis of
our observation of Mr. Frank’s candor, sincerity, and demeanor
perceived him to be of little help to the Court in deciding these
cases. As to Mr. DeWeese, we have respected his testimony and
given that testimony appropriate weight. When Mr. DeWeese
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