- 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.           
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