-20- ability to obtain contracts from all over the world. Mr. Leonard was dedicated to his work and essential to petitioner's business. While Mr. Leonard was the driving force behind petitioner, he was in the process of retiring during the year in issue and reduced his workload to 7-8 hours a day, 6 days a week. While these hours are less than he worked in previous years, Mr. Leonard's reduced workload must be balanced against his 40 years of knowledge and experience in the industry. We are mindful that petitioner's sole activity during the year in issue was to report income, which had previously been earned, on a contract-completed basis. However, because part of the bonus was attributable to Mr. Leonard's past services, we consider this fact unimportant. Finally, Mr. Leonard personally guaranteed petitioner’s $1.5 million debt to the Royal Bank of Canada. While Mr. Leonard testified that guaranteeing debts was his normal method of conducting business, we believe that the personal guaranty further illustrates Mr. Leonard's importance to petitioner. See Owensby & Kritikos, Inc. v. Commissioner, supra. This factor favors petitioner. (2) External Comparison This factor compares the employee’s compensation with that paid by similar companies in similar industries for similar services.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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