Miller & Sons Drywall, Inc. - Page 17

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          compensation than he had during the June 30, 1996, tax year.                
          These facts do not support a conclusion that during the years in            
          issue, petitioner was making catchup payments for the years prior           
          to 1997.  Of the years in issue, only for the tax year ended June           
          30, 2000, did petitioner’s shareholder-employees receive                    
          compensation over that paid in 1996.  The record establishes that           
          this increase resulted from petitioner’s obtaining its most                 
          profitable job ever, not from petitioner’s intention to remedy              
          past undercompensation.  Even if petitioner intended some of the            
          payments in issue to remedy past undercompensation, petitioner              
          failed to establish the amount of the past undercompensation or             
          how much catchup compensation was allegedly paid during each year           
          in issue.  Therefore, we hold that none of the compensation                 
          petitioner paid for the years in issue was to remedy past                   
          undercompensation.                                                          
               We do not include this as a factor in our reasonableness-of-           
          the-compensation analysis because such a finding would not                  
          necessarily indicate the shareholder-employees were                         
          overcompensated.  Instead, that analysis is based on the factors            
          discussed below.                                                            
          VI. Application of Reasonable Compensation Factors                          
               A.   Employee Qualifications                                           
               An employee’s superior qualifications may justify high                 
          compensation for his services.  See Charles Schneider & Co. v.              






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