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Respondent speculates that Choate did not work as many hours
as he claimed. However, no witness contradicted Choate's
testimony about his own efforts, and Page, petitioner's chief
financial officer, testified that he had never known anyone that
worked as hard as Choate.
Respondent contends that it is common for a CEO to work long
hours, suggesting that Choate's schedule was nothing out of the
ordinary. However, respondent produced no evidence that CEO's
commonly work as hard as Choate did.
Respondent points out that Choate was quoted in a magazine
article giving Barrett, Freese, and Dudley credit for helping
petitioner become successful. This fact is not contrary to the
conclusion that Choate was more important to petitioner than his
assistants.
This factor favors petitioner.
3. Size and Complexity of the Business
The size and complexity of a taxpayer's business are factors
in deciding whether compensation is reasonable. Rutter v.
Commissioner, supra; Pepsi-Cola Bottling Co. v. Commissioner, 528
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