Summit Sheet Metal Co. - Page 19

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               Petitioner contends that a suitable replacement could                  
          perform the job of each officer.  Petitioner’s point does not               
          establish much because it does not address how difficult it would           
          be or what amount of pay would have been required to find someone           
          suitable.                                                                   
               This factor tends to show that the compensation at issue was           
          reasonable.                                                                 
                    b.   Nature, Extent, and Scope of Duties                          
               The position held by the employee, hours worked, and duties            
          performed may justify high compensation.  Mayson Manufacturing              
          Co. v. Commissioner, supra; see, e.g., Elliotts, Inc. v.                    
          Commissioner, supra 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); Home Interiors &                 
          Gifts, Inc. v. Commissioner, supra at 1158.                                 
               Petitioner contends that its officers had minimal                      
          responsibilities.  We disagree.  Each officer was responsible for           
          an important part of petitioner's operations.  Petitioner's                 
          officers did not know how to perform each other's jobs.  This               
          made each of them less valuable to petitioner.  By the year in              
          issue, petitioner was a well-established and stable business.               
          Petitioner's officers were no doubt required to work less than if           
          petitioner had been a new business.                                         







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