PMT, INC. - Page 20

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          creditors.  Mr. Dubner's interest was not in the reasonableness             
          of salaries paid to officers, but rather the capital of the                 
          company.  Mr. Dubner's testimony, therefore, is of little, if               
          any, value on the issue of reasonable compensation.  His interest           
          was solely whether the 1990 officers' compensation paid by                  
          petitioner would adversely affect petitioner's ability to pay its           
          bills.                                                                      
               Petitioner's accountant, Mr. Blumberg, was called as a                 
          witness by petitioner to testify as to the reasonableness of the            
          Penalbas' compensation.  The Court ruled that consideration of              
          Mr. Blumberg's testimony would be limited to the financial data             
          he had prepared.  Mr. Blumberg utilized the Robert Morris                   
          Associates 1990 Annual Statement Studies (RMA).  The RMA is                 
          heavily relied on by credit managers and officers at banks,                 
          factors, and trade creditors.  The RMA lists comparables by their           
          Standard Industrial Classification (SIC) code.  Mr. Blumberg                
          utilized the SIC code 2257, which includes operations that are              
          "establishments primarily engaged in knitting weft (circular)               
          fabrics or in dyeing, or finishing weft (circular) knit fabrics."           
          This definition includes converting operations.  Mr. Blumberg               
          determined that it was inappropriate to classify petitioner as an           
          apparel maker, fabric producer, or distributor, because these               
          operations produce woven fabrics that are rarely produced in the            
          U.S. and are generally produced on a much greater scale than knit           
          fabrics.  In comparison with woven fabric operations, operations            




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