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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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