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methods presented by the experts constitute advocacy. Laureys v.
Commissioner, 92 T.C. 101, 127-129 (1989); see also Estate of Halas
v. Commissioner, 94 T.C. 570, 578 (1990).
With regard to the instant case, in some instances,
petitioner's experts were nothing more than advocates for their
client and in those instances, we dismissed their conclusions;
however, in other instances, we found the experts' testimony
credible and thus accepted that part, as discussed infra.
Our disagreement with the analyses performed by petitioner's
experts was limited to their determination of exaggerated figures--
Mr. Wagner advocated a bonus in the $1.2 million to $2 million
range, and Mr. Kesner believed Mr. Leonard was undercompensated by
$2,050,000 to $2,700,000. With regard to the opinion of Mr.
Brennan, respondent's expert, we rejected it because Mr. Brennan
relied upon information from businesses different than petitioner's
in reaching a result that understated reasonable compensation.
Notwithstanding the aforesaid, given the relative proximity of
the figures between petitioner's and respondent's experts with
respect to the base salary and retirement components, we found both
Mr. Wagner's base salary figures ($180,000 to $200,000) and Mr.
Kesner's retirement figure ($296,000) to be reasonable, as
discussed infra.
Third, Mr. Leonard's new insulation process promoted
petitioner's business. Also, the ratio of Mr. Leonard's bonus to
petitioner's taxable income before the compensation deduction was
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