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Petitioner next refers to the nature, extent, and scope of
Mr. Schoenecker's work at BI. Petitioner states that it is no
small task to be the person responsible for keeping over 750
employees, including such diverse groups as salespeople, creative
personnel, and accounting personnel moving in the same direction.
However, this is the normal expected job of a CEO, and though a
lack of ability in that area might warrant less compensation,
competence in that area is expected. Nevertheless, we consider
Mr. Schoenecker to have been shown by this record to be a CEO who
kept close tabs on the work of his organization in a very
competent manner. Petitioner states that Mr. Schoenecker's
duties included those of CEO, as well as chief operating officer,
and chief quality officer. However, the record shows that there
were a number of other competent employees in BI, and Mr.
Schoenecker's work was primarily that of the CEO. Certainly as
the CEO, he had general supervision and control over operations
and quality of the work, but he did have other competent officers
to perform the daily aspects of that work. Mr. Schoenecker, as
CEO, had final responsibility of all aspects of BI's business.
Mr. Schoenecker's devotion to the business is certainly
unquestioned on this record. He had been with the company since
its inception, and was the sole owner of the company during the
years here in issue. The record shows he worked 60- to 70-hour
weeks, but this again is not uncommon for a CEO, nor is it
necessarily one of the prime criteria on which to judge the
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