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          October 26, 1988, shows that petitioner's compensation of its               
          officers exceeds the average amount paid by similar firms.                  
          However, this does not establish that the compensation of                   
          petitioner's officers was unreasonable because the SMACNA survey            
          also shows petitioner performed considerably better financially             
          than the SMACNA survey respondents.                                         
               SMACNA sent each member a questionnaire asking for financial           
          information, such as gross profit, gross sales, and executive               
          compensation.  Forty-one SMACNA survey respondents had sales of             
          more than $8.2 million.  The following chart compares the SMACNA            
          survey results for these respondents with data for petitioner for           
          the year in issue.                                                          
                              SMACNA survey respondents                               
                              with sales over $8.2 Million                            
               Net income                        SMACNA                               
               before tax as a --                average    Petitioner                
               Percent of sales                  3.5        10.3                      
               Percent of assets                 9.3        22.5                      
               Percent of net worth              25.0       33.0                      
               The 41 respondents had an average gross profit margin of               
          18.8 percent of sales; petitioner had 41 percent in the year in             
          issue.  Petitioner's financial performance was superior to that             
          of SMACNA survey respondents which had sales exceeding $8.2                 
          million.                                                                    
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