Alpha Medical, Inc., f.k.a. Alpha Medical Management, Inc. - Page 29

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          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 functions                   





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