- 27 -
performance or that the other companies were as successful as
quickly as petitioner. Brennan's analysis is not helpful because
he has not shown that he considered comparable firms and
executives. We have said this about Brennan's testimony in other
cases. E.g., Lumber City Corp. v. Commissioner, T.C. Memo. 1996-
171; Pulsar Components Intl., Inc. v. Commissioner, T.C. Memo.
1996-129; Alondra Indus., Ltd. v. Commissioner, T.C. Memo. 1996-
32; Guy Schoenecker, Inc. v. Commissioner, T.C. Memo. 1995-539;
Mad Auto Wrecking, Inc. v. Commissioner, T.C. Memo. 1995-153.
Kirkland's opinion is that reasonable compensation to Choate
for 1990, 1991, and 1992 would have been an average of $539,416
per year. Kirkland based this amount in part on Choate's pay
from Toon, his prior service to petitioner, the absence of
benefits from petitioner, petitioner's return on equity, and
Choate's success with petitioner.2 Choate's pay from petitioner
from 1990 to 1992 averaged $456,000. Kirkland said this was
2 Kirkland noted that he found no boats or lakehouses, or
relatives on petitioner's payroll, leading him to observe that
petitioner is a very "clean" organization.
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