Choate Construction Co. - Page 16

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            Dudley's and Freese's testimony that they were important to                                  
            petitioner and Dudley's testimony that Choate was not.                                       
                  We do not consider events occurring after June 30, 1992, in                            
            deciding the value of Choate's services in petitioner's fiscal                               
            year ending on that date, see Estate of Gilford v. Commissioner,                             
            88 T.C. 38, 52-55 (1987), except as stated next.  We consider                                
            Choate's 1993 Entrepreneur of the Year award as evidence that his                            
            1992 compensation was reasonable because the selection process                               
            for the 1993 award had begun in 1992, and we believe that                                    
            petitioner knew before June 30, 1992, about most or all of                                   
            Choate's accomplishments that led to his receipt of the 1993                                 
            award.  We do not consider petitioner's growth from 1993 to 1995                             
            in deciding Choate's value to petitioner in 1992 because                                     
            petitioner did not show that it knew in 1992 that the growth                                 
            would occur.                                                                                 
            C.    Reasonableness of Choate's Compensation                                                
                  We next apply the factors listed above at paragraph B-1 in                             
            deciding whether the compensation petitioner paid to Choate was                              
            reasonable.                                                                                  














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