- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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