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significant in determining reasonable compensation. Owensby &
Kritikos, Inc. v. Commissioner, supra at 1330; Charles Schneider
& Co. v. Commissioner, 500 F.2d 148, 154-155 (8th Cir. 1974),
affg. T.C. Memo. 1973-130; sec. 1.162- 7(b)(3), Income Tax Regs.
As Kleindienst performed numerous functions, the relevant
comparison is to the salaries of each position she filled.
Elliotts, Inc. v. Commissioner, 716 F.2d at 1245.
At trial, both parties presented expert testimony as to what
a similar escrow firm would pay for Kleindienst's services.
Petitioner called Larri Jones as an expert witness. Jones
supervises escrow operations at Chicago Title and determines
compensation for escrow officers. Chicago Title pays its escrow
officers a base salary of $36,000 to $60,000 plus commission.
Jones described three types of commission. The first commission
is paid to escrow officers based on escrow fees they generate by
closing escrows (closing commission). To earn this commission,
an escrow officer must generate fees over a predetermined
threshold. Once over the threshold, an officer earns a
commission of 25 to 31 percent of the closing fees generated; the
exact percentage depends on the officer's responsibilities, such
as hiring, overseeing escrow accounts, and marketing. The second
commission is earned by an escrow officer who manages escrow
operations (management commission). An escrow manager receives
an additional 2 to 4 percent of revenue generated by officers
under her supervision. The third commission is paid to
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