- 16 - experience in the health care industry. Furthermore, Rogers developed a single drugstore into a chain of stores that he sold in 1986 and a hospital supply business that he sold to a publicly traded company in 1984. Rogers was instrumental in developing petitioner's computer software programs, mock surveys, and policy manuals, solving its staffing problems, and developing cost-efficient operating procedures. Petitioner's success is mainly attributable to Rogers' ambition, creativity, vision, and energy, not to its investment in capital. See Home Interiors & Gifts, Inc. v. Commissioner, supra at 1158; Dave Fischbein Manufacturing Co. v. Commissioner, supra. This factor favors petitioner. 2. Nature, Extent, and Scope of Rogers' Work An employee's position, hours worked, duties performed, and general importance to the success of a business may justify high compensation. Home Interiors & Gifts, Inc. v. Commissioner, supra at 1158. In this case, the history of Rogers' contributions to petitioner must be considered, rather than just his contributions during the year at issue, because the compensation petitioner paid to him during the year at issue represents, in part, an attempt to rectify prior undercompensation. (See our discussion under factor 9, infra.) At one time or another since its inception, Rogers has held most of the management positions at petitioner. He hasPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011