Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 35

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          indicates that he actually did so in 1986-87.  The record does              
          not indicate that Mr. Munro devoted any more than minimal time to           
          petitioners' affairs during the years in question.  Moreover, the           
          record indicates a sharp rise in Mr. Munro's compensation for               
          1987 without any concomitant growth of the associated                       
          enterprises.                                                                
               This factor supports allowing a deduction for payments to              
          Mr. Munro of no more than the normal pay of a chief executive               
          officer in the industry.                                                    
               (b) External Comparison                                                
               This factor requires a comparison of the employee's                    
          compensation with that paid by similar companies for similar                
          services.  Elliotts, Inc. v. Commissioner, supra at 1246.  Courts           
          often regard this as the most important factor and receive                  
          testimony on the subject from competing experts.  In these cases,           
          however, we have only the testimony of respondent's expert, E.              
          James Brennan III (Mr. Brennan).  As we have previously noted,              
          Mr. Brennan is no stranger to this Court in that capacity.  Mad             
          Auto Wrecking, Inc. v. Commissioner, T.C. Memo. 1995-153.  The              
          method that Mr. Brennan has used to try to determine reasonable             
          compensation for Mr. Munro is similar to Mr. Brennan's method in            
          other recent cases.  Mr. Brennan uses data published in executive           
          compensation surveys to derive equations relating total revenues            
          of a business to the compensation paid to  its officers.                    






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