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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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