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its employees, both shareholders and nonshareholders, it may be
able to justify a higher compensation level to its shareholder-
employees. Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d
at 1324. In addition, a longstanding, consistently applied
compensation plan indicates that compensation is reasonable.
Elliotts, Inc. v. Commissioner, supra at 1247.
Petitioner paid bonuses to all employees, but petitioner
did not pay bonuses to its nonshareholder escrow officers in a
manner consistent with which it paid Kleindienst. Petitioner
paid its escrow officers a closing commission of 10 percent of
fees from escrows that they closed. Expert witnesses from both
parties stated that escrow officers commonly make about one-
third of the closing fees as commission. Petitioner never
explained why its compensation plan for its escrow officers
differed from the industry norm. These officers also solicited
escrows without additional commission. In total, petitioner's
other escrow officers received salary, commission, and bonuses
of $218,763 and $248,091, while Kleindienst made $584,710 and
$564,800 during the years in issue, respectively. In addition,
Kleindienst's compensation exceeded the combined compensation of
all of petitioner's other 21 employees by $127,419 in taxable
year 1989 and its other 23 employees by $79,494 in taxable year
1990. The disparity between Kleindienst's compensation and that
of the nonshareholder escrow officers is patently glaring
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