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granted them can often prove highly remunerative. However, as
discussed previously, Mr. Martin generally does not appear to
have been undercompensated in prior years. Also, we have no way
of knowing the specific stock options petitioner's experts
believed Mr. Martin, hypothetically, should otherwise have
received, as they provided no further elaboration in connection
with this point. The same is true of Jones' contentions about
royalties.
With respect to petitioner's expert Jones' claim that Mr.
Martin could have taken even more compensation from petitioner,
we find questionable her suggestion that he performed the work of
four full-time executives serving as petitioner's chief executive
officer, vice president for marketing, vice president for sales,
and chief technical officer. Although Mr. Martin may have
performed some of the duties and functions of four such
executives, he did not perform work equal to the full-time
services of four such executives. Indeed, by the 1990 fiscal
year in issue, he was devoting some of his time and attention to
his other company, Caribe.6
In sum, petitioner's experts have failed meaningfully to
6To be sure, this Court and other courts in numerous
reasonable compensation cases have considered the fact that the
recipient performed more than one function for his employer, even
though that individual's reasonable compensation may not be the
sum of the amounts paid to a full-time employee in each such
position. See PMT, Inc. v. Commissioner, T.C. Memo. 1996-303.
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