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an investment in petitioner. See Elliotts, Inc. v. Commissioner,
716 F.2d at 1245; Haffner’s Serv. Stations, Inc. v. Commissioner,
supra.
We are assisted in this case by Wertlieb. In light of his
qualifications and with due regard to all other credible evidence
in the record, we consider Wertlieb’s training, knowledge, and
judgment to be most helpful to our understanding of the executive
compensation issue at hand. See Fed. R. Evid. 702; Snyder v.
Commissioner, 93 T.C. 529, 534 (1989). Wertlieb testified at
trial through his expert report (report). See Rule 143(f). The
Court accepted that report into evidence without any objection
from respondent. Respondent also declined to cross-examine
Wertlieb as to its contents.
We turn to the five factors and analyze them seriatim. None
of these factors is decisive in and of itself. LabelGraphics,
Inc. v. Commissioner, 221 F.3d at 1095.
1. Employee’s Role in the Company
We analyze Beiner’s role in petitioner’s business. A
relevant consideration is his general importance to petitioner’s
success. See Elliotts, Inc. v. Commissioner, supra at 1245.
Other considerations include his position, hours worked, and
duties performed. See id.
Beiner is an experienced electrical designer who had the
devotion, dedication, intelligence, foresight, and skill to
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