-24- reasonable range for Mr. Leonard's 1987 base salary was $180,000- $200,000; a reasonable range for his 1987 bonus was $1,200,000- $2,000,000. Mr. Kesner is an expert specializing in compensation matters for Arthur Andersen in Chicago.10 He concluded that Mr. Leonard’s 1987 compensation was reasonable for three alternative reasons: (1) Mr. Leonard was undercompensated by $2,005,000-$2,700,000 in prior years; (2) the compensation was a deal bonus for locating and delivering profitable business opportunities; and (3) part of the bonus was a lump-sum payment in lieu of a formal retirement plan. Mr. Kesner used survey data, and assumed revenues of $40 million for each of the years. We are unpersuaded by the analyses performed or opinions expressed by either respondent’s or petitioner’s experts. As in previous cases, we do not accept Mr. Brennan's conclusions because they are not based on data from businesses that are sufficiently similar to petitioner’s or that have the significant characteristics of a specialized industry. Messrs. Wagner and Kesner were also unconvincing because they were not objective and simply promoted petitioner’s position. See Laureys v. Commissioner, 92 T.C. 101, 129 (1989). We do not accept their conclusions. 10 Mr. Kesner was not involved in Arthur Andersen's 1987 advice to Mr. Perks and petitioner.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011