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experience in the health care industry. Furthermore, Rogers
developed a single drugstore into a chain of stores that he sold
in 1986 and a hospital supply business that he sold to a publicly
traded company in 1984.
Rogers was instrumental in developing petitioner's computer
software programs, mock surveys, and policy manuals, solving its
staffing problems, and developing cost-efficient operating
procedures. Petitioner's success is mainly attributable to
Rogers' ambition, creativity, vision, and energy, not to its
investment in capital. See Home Interiors & Gifts, Inc. v.
Commissioner, supra at 1158; Dave Fischbein Manufacturing Co. v.
Commissioner, supra. This factor favors petitioner.
2. Nature, Extent, and Scope of Rogers' Work
An employee's position, hours worked, duties performed, and
general importance to the success of a business may justify high
compensation. Home Interiors & Gifts, Inc. v. Commissioner,
supra at 1158. In this case, the history of Rogers'
contributions to petitioner must be considered, rather than just
his contributions during the year at issue, because the
compensation petitioner paid to him during the year at issue
represents, in part, an attempt to rectify prior
undercompensation. (See our discussion under factor 9, infra.)
At one time or another since its inception, Rogers has held
most of the management positions at petitioner. He has
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