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justify high compensation. Petitioner's profitability, which
rests upon its sales, and the Officers' ambition, inventiveness,
and energy (as opposed to petitioner's investment in capital) are
the primary reasons for petitioner's sales, growth, and success.
See Home Interiors & Gifts, Inc. v. Commissioner, supra at 1158;
Dave Fischbein Manufacturing Co. v. Commissioner, supra at
352-353. This factor favors petitioner.
c. Nature, Extent, and Scope of the Employee's Work
An employee's position, hours worked, duties performed, and
general importance to the success of a business may justify high
compensation. Elliotts, Inc. v. Commissioner, 716 F.2d at
1245-1246; American Foundry v. Commissioner, 536 F.2d 289,
291-292 (9th Cir. 1976), affg. in part and revg. in part 59 T.C.
231 (1972); Mayson Manufacturing Co. v. Commissioner, supra; Home
Interiors & Gifts, Inc. v. Commissioner, supra at 1158.
The Officers performed all of petitioner's executive and
managerial functions. They performed or oversaw virtually all of
its trading activities. They supervised its daily operations,
including supervising and directing its employees, and they made
its business decisions. Given the vital role played by the
Officers in petitioner's operations and success, and the long
hours that they each dedicated thereto, we view the Officers as
indispensable to petitioner's business. Petitioner's growth and
prosperity are due directly to their skills, dedication, and
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