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consistently worked 12 hours each day in the office and is on
call 24 hours a day. Rogers' responsibilities have covered a
wide range of activities, including sales, personnel, operations,
finance, planning, and flying the corporate airplane.
The record shows that no other officer of petitioner has the
breadth of experience with the company which Rogers has.
However, his experience has not been a solitary one; he has been
assisted by a hard-working and well-qualified management team,
and in particular by Worley.
By any reasonable measure, Rogers' efforts on behalf of
petitioner have been highly successful. Petitioner's
profitability is attributable to sales of its services and
effective cost containment. "Getting and keeping customers is,
of course, the lifeblood of any business". Kennedy v.
Commissioner, 671 F.2d 167, 176 (6th Cir. 1982), revg. 72 T.C.
793 (1979). Rogers is petitioner's primary salesman and deal
closer; he personally obtained each of petitioner's clients and
negotiated each contract petitioner made with its clients.4
Since 1986, petitioner's gross receipts have increased
almost 12 times, taxable income has increased almost 18 times,
and net worth has shown an increase of over 35 times. See Home
4 We note, however, that Tankersly and Worley also
entertained and recruited clients, and since 1989, Stees'
responsibilities have included developing and maintaining client
relationships.
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