Labelgraphics, Inc. - Page 24

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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              
               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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