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for FY-88, $380,490 to $408,300 for FY-89, $422,500 to $460,690
for FY-90, and $435,060 to $483,200 for FY-91." The minimum of
this range was in excess of the amount determined by respondent
in the notice of deficiency to be reasonable compensation.
Respondent, of course, based this requested finding on her
interpretation of the evidence as a whole. However, a review of
the report of respondent's expert witness, Mr. Brennan, indicates
that the ranges probably came to an appreciable extent from his
report. The ECS figures included in that report by Mr. Brennan
contained, as we have stated, amounts of "maximum" amounts paid
to CEO's of companies in business services and wholesale trade
which receive revenues comparable to those received by GSI and
subsidiaries in the years 1988 through 1991. Mr. Brennan's
report stated that to justify a salary of this amount Mr.
Schoenecker would have to be the outstanding executive in the
entire country, which, in Mr. Brennan's opinion, the record did
not support. It is not absolutely clear how the "maximum"
amounts of compensation were computed in the ECS statistics. It
does appear that this amount is basically the top salary paid to
an executive of a company in the business services and wholesale
trades industry, the revenues of which were comparable to those
of BI. Although we recognize that the business services and
wholesale trade industries are not good comparisons on an average
basis to petitioner's more limited type of business, it appears
to us that a reasonable salary for Mr. Schoenecker would not be
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