- 35 -                                         
          also reject the opinion of an expert witness in its entirety.               
          Palmer v. Commissioner, 523 F.2d 1308, 1310 (8th Cir. 1975),                
          affg. 62 T.C. 684 (1974); Parker v. Commissioner, supra at 562-             
          565.                                                                        
               Respondent relies on the opinions of E. James Brennan III              
          (Mr. Brennan), the president of a personnel and pay practice                
          consulting firm.  Using statistical analyses that compared the              
          ratios of CEO compensation to total sales based on survey data              
          collected by the Wyatt Executive Compensation Service (ECS), Mr.            
          Brennan concluded that the following is the highest maximum                 
          compensation to which Mr. Ruf was entitled for each of the years            
          indicated:                                                                  
                       Year Ended            Maximum Compensation                     
                       Feb. 28, 1989                 $389,760                         
                       Feb. 28, 1990                  368,190                         
                       Feb. 28, 1991                  914,490                         
               We are unwilling to rely on Mr. Brennan's analyses or his              
          opinions.  One of the principal problems we have with his anal-             
          yses is that we are not persuaded that the ECS survey data on               
          which they were based are data obtained from companies that are             
          comparable to petitioner.  For example, Mr. Brennan used data he            
          obtained from the broad category of retail trade, rather than a             
          narrower category of retail home centers.  In fact, there is no             
          evidence that a single home center was included in the survey               
          data on which Mr. Brennan relied.  Moreover, although petitioner            
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