Brewer Quality Homes, Inc. - Page 27

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          the degree of Ph.D. in Economics by the University of Minnesota.            
          He has testified as an expert witness in reasonable compensation            
          cases.                                                                      
               Table 5 shows the amounts that Hakala concluded were maximum           
          reasonable compensation for Jack’s services to petitioner in                
          1994, 1995, and 1996, per Hakala’s expert witness report (Ex. 60-           
          R) and Hakala’s rebuttal expert witness report (Ex. 61-R).                  
                                       Table 5                                        
                                   Ex. 60-R          Ex. 61-R                         
          1994          $381,608          $410,626                                    
          1995           544,419           599,117                                    
          1996           448,620           485,966                                    
               The task of calculating a maximum amount of reasonable                 
          compensation ordinarily, and in the instant case, involves                  
          judgment calls, generalizations, and very rough approximations.             
          We are mindful of Judge Tannenwald’s observation that in                    
          valuation disputes (and reasonable compensation disputes are                
          essentially a subset of valuation disputes) there is often “an              
          overzealous effort, during the course of the ensuing litigation,            
          to infuse a talismanic precision into an issue which should                 
          frankly be recognized as inherently imprecise”.  Messing v.                 
          Commissioner, 48 T.C. 502, 512 (1967); see Estate of Jung v.                
          Commissioner, 101 T.C. 412, 446 (1993).                                     
               Hakala acknowledges that the correction of but one set of              
          inconsistencies in his expert witness report assumptions results            






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