Sunbelt Clothing Company, Inc., f.k.a. Unprinted T-Shirt Warehouse, Inc. - Page 14

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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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