Guy Schoenecker, Inc., Business Incentives, Inc., and Carousel By Guy, Inc. - Page 35

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            greater than the top salaries paid.  If, in fact, petitioner had                               
            been among the companies included in the ECS report, the salary                                
            paid to Mr. Schoenecker would have been the top salary since it                                
            exceeded the top salary shown in the ECS report.  However, BI and                              
            GSI were not public companies, the financial operations of which                               
            were available to ECS from published sources.  It appears that                                 
            neither BI nor GSI information was reported to ECS.  Another                                   
            difficulty with the ECS statistics is the difference in the                                    
            number of companies included in different years.  However, we                                  
            have compared the figures of the top salaries in the business                                  
            services and wholesale trade classification for the years 1988                                 
            through 1991 with the salaries paid by advertising firms that                                  
            were close in size to BI.  Overall the top salaries in the                                     
            business services and wholesale trade classification are in                                    
            excess of the salaries paid by advertising firms of the                                        
            approximate size of BI.  According to petitioner's witness, the                                
            salaries in the business services and wholesale trade industries                               
            did not include certain fringe benefits, such as retirement pay.                               
            However, there is nothing to show that in addition to the                                      
            reported salaries, such fringe benefits were paid by the                                       
            companies.  The ECS figures of top pay in the business service                                 
            and wholesale industry are also in total in excess of the amount                               
            of salary that would have been paid to Mr. Schoenecker under the                               
            1974 agreement for the years here in issue.  We are aware, of                                  
            course, that under an arm's-length arrangement, the base salary                                



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