- 28 -
for comparable positions in comparable concerns. Considering his
testimony in its entirety, we find that Mr. Dorf was retained by
petitioner to advocate its position herein. See Laureys v.
Commissioner, 92 T.C. 101, 129 (1989). We are no more convinced
by Mr. Brennan. We have had difficulty accepting Mr. Brennan's
"expert" opinions in previous cases. As in the past, we have
trouble accepting his conclusions as they are not based on data
from businesses that are akin to the business at hand; i.e.,
third-tier supply firms in the computer chip and semiconductor
industry. Restating what we have previously stated with respect
to Mr. Brennan's "expert" testimony: "We are not satisfied that
a reasonable level of compensation for an executive like * * *
[the Officers] can be accurately determined by reference to the
industries Brennan surveyed because of the absence of significant
information on other businesses similar to petitioner's."
Mad Auto Wrecking, Inc. v. Commissioner, supra (quoting
Thomas A. Curtis, M.D., Inc. v. Commissioner, T.C. Memo.
1994-15). Indeed, comparing compensation paid to officers of
companies that differ markedly provides guidance of dubious
value. See Diverse Indus., Inc. v. Commissioner, T.C. Memo.
1986-84; Niagara Falls Coach Lines, Inc. v. Commissioner, T.C.
Memo. 1977-269. This factor favors neither party. We consider
it neutral.
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