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Cir. 1977); Garnac Grain Co. v. Commissioner, 95 T.C. 7, 26-27
(1990), and we do not rely on the respective opinions of Dr.
Barren and Dr. Vinso concerning such matters.
With respect to Dr. Barren, we found him to be evasive at
times when questioned on cross-examination. For example, he was
unwilling to give his opinion on cross-examination of the maximum
amount of Mr. Ruf's compensation for the years at issue that he
considered reasonable. In addition, we found Dr. Barren's analy-
ses to be flawed in a number of respects. By way of illustra-
tion, when Dr. Barren analyzed the compensation paid by each
company that he found to be comparable to petitioner, he con-
cluded that Mr. Ruf was entitled to compensation that was equal
to the total officer compensation, rather than just the CEO
compensation, paid by each such allegedly comparable company.
However, he failed to compare the roles undertaken by all the of-
ficers at each of those allegedly comparable companies with the
roles undertaken by Mr. Ruf at petitioner. Thus, we are not
persuaded that Mr. Ruf is entitled to the compensation of all the
officers of any of those allegedly comparable companies.
With respect to Dr. Vinso, we found his testimony to be at
times contradictory and evasive. For example, when asked on
cross-examination, Dr. Vinso was unwilling to say whether or not
there was a statistical correlation between a company's asset
size and the ratio of its officer compensation to its sales. In
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