- 31 -
or her investment. See Rapco, Inc. v. Commissioner, supra at
954-955.
In performing our analysis, we review Mr. Wechsler’s, Mrs.
Wechsler’s, and Gilbert’s compensation separately because whether
the compensation that petitioner paid to each is reasonable
depends on the services he or she performed. See Miller & Sons
Drywall, Inc. v. Commissioner, supra.
III. Expert Reports
A. Introduction
Both parties offered expert testimony in support of their
respective positions concerning reasonable compensation for Mr.
Wechsler. No expert testimony was offered concerning reasonable
compensation for either Mrs. Wechsler or Gilbert.
In deciding the reasonableness of compensation, courts often
look to the opinions of expert witnesses. Nonetheless, we are
not bound by the opinion of any expert witness, and we may accept
or reject expert testimony in the exercise of sound judgment.
Helvering v. Natl. Grocery Co., 304 U.S. 282, 295 (1938);
Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976) (and
cases cited thereat), affg. T.C. Memo. 1974-285. Although we may
accept the testimony of an expert in its entirety, see Buffalo
Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452
(1980), we may be selective in determining what portions of an
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