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reports of CEO's of business services and wholesale companies
receiving comparable revenues to those received by BI, than to
use the amount computed under petitioner's 1974 salary agreement
with BI. It is certainly more favorable than using the salary
payments from advertising companies in the same general revenue
receipt area as BI, unless they are to be substantially increased
for items which it is not clear were not already included, or
were benefits which were not part of the compensation of the
officer involved. It is not unusual that higher cash
compensation be paid to an officer who does not receive noncash
benefits.
Therefore, considering this record as a whole, and being
unwilling to sustain respondent's determination on the basis of
failure of proof by petitioner, we conclude that the evidence
most indicative of a proper amount to be paid to Mr. Schoenecker
in each of the years here in issue from this record is the
"maximum" amounts paid CEO's of companies in business services
and wholesale trade that received revenues comparable to those
received by GSI as shown by the ECS survey for the years 1988
through 1991. These amounts are $703,530 in BI's fiscal year
1988, $779,550 in BI's fiscal year 1989, $882,680 in BI's fiscal
year 1990, and $838,970 in BI's fiscal year 1991. Therefore,
based on this record as a whole, and considering the outstanding
contribution Mr. Schoenecker made as CEO of BI, we hold that the
above-set forth amounts constitute reasonable compensation to Mr.
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