Wagner Construction, Inc. - Page 22




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          selective in deciding what part of an expert witness' report we             
          will accept.  See Helvering v. National Grocery Co., 304 U.S.               
          282, 295 (1938); Silverman v. Commissioner, 538 F.2d 927, 933 (2d           
          Cir. 1976), affg. T.C. Memo. 1974-285; Parker v. Commissioner, 86           
          T.C. 547, 561 (1986).                                                       
               1.  Robert F. Reilly                                                   
               Petitioner presented the report and testimony of Robert F.             
          Reilly (Mr. Reilly), a compensation expert and a business                   
          valuation expert from the firm of Willamette Management                     
          Associates.                                                                 
               In order to prepare his report, Mr. Reilly reviewed                    
          petitioner's Forms 1120 and financial statements covering periods           
          from 1986 to 1996.  He interviewed Dennis and reviewed various              
          documents produced by petitioner, respondent, and third parties             
          to obtain information regarding petitioner and the services                 
          provided by Dennis and Curtis.  Mr. Reilly researched the                   
          published proxy data of public companies in 1995 and 1996 in an             
          effort to find companies comparable to petitioner but found no              
          specific public companies comparable to petitioner for                      
          compensation purposes.  Additionally, he used various surveys to            
          evaluate the compensation paid to Dennis and Curtis in 1995 and             
          1996.                                                                       
               Mr. Reilly considered developments of petitioner's business            
          from 1986 through 1996, including the following:                            






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