- 33 - relied upon by Hughes' and Benesh's report supports their conclusion. Hughes' and Benesh's total disregard of the actual amounts paid to those who, in their opinion, perform jobs requiring functions comparable to those required of Rogers is suspect. Thus, we find petitioner's experts' opinions of dubious value. Respondent's Witness Respondent chose not to rely upon an expert witness for an opinion and chose instead to rely upon Revenue Agent Horton to explain how he determined $400,000 was the reasonable amount of compensation for petitioner to pay Rogers. Horton is not an expert on compensation. Horton based his determination of the compensation that would be reasonable upon his experience as an IRS agent, and some general statistics on the average compensation paid to an officer of a business of approximately the same size as petitioner. There is no evidence that Horton based his determination on the prevailing rates of compensation for comparable positions in comparable concerns. Therefore, we accord Horton's testimony regarding this factor no weight. This factor favors neither party. We consider it neutral. 8. Salary Policy of Petitioner as to All Employees Courts have considered salaries paid to other employees of a business in deciding whether compensation is reasonable. Kennedy v. Commissioner, 671 F.2d at 173; Home Interiors & Gifts, Inc. v.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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