- 23 -
technical officer. She further asserted that he would have been
entitled to royalties on petitioner's clean room labels, as chief
technical officers of hi-tech companies typically will receive a
royalty on the sales of any products they help develop.
Culbertson and Jones failed to offer any details concerning
the specific high-technology companies upon which they based
their opinions. They also offered no specifics on the particular
executives involved, nor pertinent information on their
particular qualifications and skills and the exact compensation
they received. We thus are unable to determine: (1) How similar
these other unidentified companies and their businesses are to
petitioner; and (2) how similar the services their executives
rendered are to the services Mr. Martin performed.5
Moreover, even if he were not petitioner's sole shareholder,
we are skeptical that Mr. Martin, prior to and during the 1990
fiscal year, in addition to the salary and bonus he had already
received, would also have been compensated by petitioner with
stock options. We do not doubt that certain top executives of
various high-technology companies typically will receive stock
options as part of their compensation and that the stock options
5Both the parties and their experts argue at considerable
length over whether or not petitioner is a high-technology
company. Petitioner contends that it is a high-technology
company, whereas respondent contends that petitioner is not. In
our view, this dispute is neither helpful nor productive to our
resolving the instant case.
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