The Escrow Connection, Inc., A.K.A. The Escrow Connection - Page 8

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          July 31, 1989, petitioner paid its 21 employees, other than                 
          Kleindienst, a total of $457,291 in salary, commission, and                 
          bonuses; for the year ended July 31, 1990, petitioner paid its 23           
          employees, other than Kleindienst, a total of $485,306.  Thus,              
          Kleindienst's compensation exceeded the combined compensation of            
          petitioner's other employees by $127,419 and $79,494,                       
          respectively.                                                               
               Respondent determined $142,852 and $156,610 as reasonable              
          compensation for Kleindienst for taxable years ended July 31,               
          1989 and July 31, 1990, respectively, and disallowed petitioner's           
          claimed deductions for the excess.  At trial, respondent conceded           
          that compensation of approximately $300,000 per year would be               
          reasonable.                                                                 
                                       OPINION                                        
               Before addressing the reasonableness of Kleindienst's                  
          compensation, we consider the admissibility of two stipulated               
          exhibits offered by respondent.  The first exhibit is a published           
          survey of owners' compensation; the second is a published survey            
          of executive compensation.  Petitioner raised two objections to             
          the exhibits.  In the stipulation of facts, petitioner reserved             
          hearsay objections.  No testimony at trial involved the exhibits,           
          but respondent relied on the exhibits in its brief.  Petitioner             
          did not renew the hearsay objections or discuss them in its                 
          initial or reply briefs.  Therefore, we consider the hearsay                
          objections reserved in the stipulation of facts abandoned.                  



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