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After becoming petitioner's CEO, Mr. Ruf was subject to
certain arrangements concerning compensation. For example, the
$933,333 that petitioner paid to Mr. Ruf during its fiscal year
ended February 28, 1989, was awarded pursuant to the 1987 de-
ferred compensation arrangement. All of the arrangements con-
cerning Mr. Ruf's compensation were terminated prior to peti-
tioner's fiscal year ended February 28, 1990, and Mr. Ruf's
compensation for that year was not determined pursuant to a plan.
Amounts of Reasonable Compensation
Based on our review of the entire record in this case, we
find that, of the $933,333 that petitioner paid Mr. Ruf during
its fiscal year ended February 28, 1989, pursuant to the 1987 de-
ferred compensation arrangement, the following amounts are
reasonable amounts of compensation paid for services Mr. Ruf
provided to petitioner during the indicated years:
Year Ended Amount of Compensation
Feb. 28, 1987 $733,333
Feb. 29, 1988 100,000
Feb. 28, 1989 100,000
We further find that, of the $2,600,000 that petitioner paid
Mr. Ruf during its fiscal year ended February 28, 1990, the
following amounts totaling $1 million are reasonable amounts of
compensation paid for services Mr. Ruf provided to petitioner
during the years indicated:
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