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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.
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