- 27 - 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 resultsPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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