- 17 - fruition. Ginger reviewed all of petitioner's expenditures, ensured low overhead, resisted adding new employees, and insisted that petitioner grow through retained earnings. Ginger continually marketed petitioner's services. Ginger's sales and marketing abilities were described as "amazing" and "outstanding". Petitioner grew steadily from its inception in 1984, weathered the economic downturn in 1991, and began a recovery in 1992. Ginger served as the catalyst for petitioner's growth and success. 2. External Comparison We also compare the employee's salary with the salaries paid by similar companies for similar services. Sec.1.162-7(b)(3), Income Tax Regs. Both parties offered expert testimony as to what a like company would pay for like services. Both experts considered surveys of financial data on numerous organizations, including developers, builders, residential building contractors, and construction contractors in specialty trades. a. Respondent's Expert Respondent presented expert testimony from Scott D. Hakala (Hakala). Hakala reviewed the surveys of financial data and concluded that it was not very "satisfying". As a result, he relied less on the market data than he would prefer for the final conclusion. Instead, Hakala derived a formula to calculate Ginger's compensation; the formula does incorporate one aspect of the survey data.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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