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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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