Sunbelt Clothing Company, Inc., f.k.a. Unprinted T-Shirt Warehouse, Inc. - Page 22

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          percent for 1990; 65.48 percent for 1991; and 65.95 percent for             
               In addition to the fact that the increase in petitioner's              
          retained earnings most likely increased the value of its stock,             
          we believe that a hypothetical investor would have considered               
          petitioner's performance for this period impressive.5                       

          7.  Prevailing Rates of Compensation for Comparable Positions               
          in Comparable Companies                                                     

               Both petitioner and respondent rely on expert testimony with           
          respect to this factor.  We weigh an expert's testimony in light            
          of his or her qualifications and considering all credible                   
          evidence in the record.  Depending on what we believe is                    
          appropriate under the facts and circumstances of the case, we may           
          either reject or accept an expert's opinion in its entirety, or             
          accept selective portions of it.  Helvering v. National Grocery             
          Co., 304 U.S. 282, 294-295 (1938); Seagate Technology, Inc. v.              

               5These return-on-equity (ROE) figures are calculated by                
          dividing net income by the shareholder equity at the beginning of           
          the year.  Respondent argues that the petitioner's ROE should be            
          calculated using the average of the beginning and ending                    
          shareholder equity, rather than beginning equity as petitioner              
          suggests.  Respondent contends that under the average equity                
          method, petitioner's ROE during the years in issue was actually:            
          58.21 percent for 1990, 49.41 percent for 1991, and 34.80 percent           
          for 1992.  While respondent's ROE is lower, we still find the               
          figures impressive.  Thus, even if we were to adopt the average             
          equity method in calculating petitioner's ROE, the results                  
          obtained would not change our conclusion.                                   

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