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supra at 1155-1156. No single factor is determinative; rather,
we must consider and weigh the totality of facts and
circumstances in arriving at our decision. Rutter v.
Commissioner, supra at 1271; Owensby & Kritikos, Inc. v.
Commissioner, supra at 1323.
1. Employee's Qualifications
An employee's superior qualifications for his or her
position with the business may justify high compensation. See,
e.g., Home Interiors & Gifts, Inc. v. Commissioner, supra at
1158; Dave Fischbein Manufacturing Co. v. Commissioner, 59 T.C.
338, 352-353 (1972).
By virtue of their training, experience, creativity, and
dedication, both Messrs. Bennett and Sokol were exceptionally
qualified for petitioner's business. Together, they understood
and controlled every aspect of petitioner's operations. Mr.
Bennett was the creative force behind petitioner's catalog, its
sole marketing tool. Complementing Mr. Bennett's creativity was
the experience of Mr. Sokol, a textile engineer who had worked in
the textile industry for over 30 years.
Petitioner's profitability rested upon its sales. The
primary reasons for petitioner's sales, growth, and success were
Messrs. Bennett's and Sokol's ambition, creativity, vision, and
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