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piece goods, and notions". However, Mr. Brennan testified that
he was unable to state the industry petitioner was in, and was
unsure whether petitioner was, in fact, in either the wholesale
or the non-manufacturing industry. Mr. Brennan stated that he
had little, if any, knowledge of petitioner's operations, and
that there was no evidence that his statistics included any other
converting operations comparable to petitioner's. In fact,
petitioner in this case was not a wholesale operation, but rather
a manufacturing operation with its work contracted out to other
companies. Petitioner produced knitted fabric for garment
manufacturers, and was not included in the SIC code that Mr.
Brennan relied on, which specifically excluded knitted goods
operations. Petitioner was properly included in the SIC code for
manufacturers. The statistics that Mr. Brennan used from the
Conference Board data, another survey he relied on in his report,
are based on companies, all of which had annual sales of at least
$60 million, while petitioner had sales of approximately $22
million in the year here in issue. The median average company in
the ECS survey had sales of $1.7 billion, while only four
companies in the survey had sales of less than $199 million.
Even though Mr. Brennan categorized Mr. Penalba as the chief
executive officer and Mrs. Penalba as the top financial
executive, he had no information as to what duties each of the
Penalbas actually performed for petitioner. From the job
descriptions in Mr. Brennan's report, it is clear that Mr.
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