- 29 - Court to discount his opinion. For instance, in his report Fisher stated that "Rogers personally designed and implemented a computer system for * * * [petitioner]", and that "Rogers was personally involved * * * in the day-to-day operations of * * * [petitioner] from the period of 1986 through 1990." Rogers, however, testified to the contrary. Furthermore, although Fisher testified that he compared Rogers' compensation to that paid to others in comparable positions, he did not cite the sources for those comparisons in either his testimony or his report. Fisher's opinion does not appear to be based on verified factual data. Thus, we accord Fisher's opinion little weight. See Diverse Indus., Inc. v. Commissioner, T.C. Memo. 1986-84. Petitioner's other experts, Hughes and Benesh, also submitted a written report. The report coauthored by Hughes and Benesh states, however, that they "were unable to locate any comparable survey data on home health care agency managers similar to * * * [petitioner]." Hughes and Benesh, therefore, were unable to perform a direct comparison. Nor were they able to identify individuals in a similar employment position, with similar experience, qualifications, knowledge, and responsibilities to those of Rogers. Despite these obstacles, Hughes and Benesh were able to create, in their opinion, a reasonable comparison by examining the specific functionsPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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