PMT, INC. - Page 18

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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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