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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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