John L. Ginger Masonry, Inc. - Page 20

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          comparable company's chief executive officer, chief                         
          operations/administrative officer, and marketing executive ranged           
          between $476,949 and $1,910,740 in 1990 and between $555,029 and            
          $776,349 in 1992.  Wieder opined that the compensation petitioner           
          paid Ginger in 1990 and 1992 was reasonable.                                
               c. Discussion                                                          
               Respondent and respondent's expert have understated the                
          services provided by Ginger and have overstated the services                
          provided by Sawhill, Lawrence, Peterson, and Adams.  Respondent             
          contends that the latter individuals were responsible for                   
          petitioner's day-to-day operations.  We do not agree with                   
          respondent's characterization.  The record indicates that Ginger            
          played the crucial role in petitioner's operations.  Sawhill,               
          Lawrence, and Peterson completed relatively routine matters that            
          Ginger had delegated to them.  They discussed anything out of the           
          ordinary with Ginger.  Adams had limited authority over the                 
          jobsites that he supervised, including the authority to hire and            
          terminate new employees on those sites.  Ginger made all other              
          personnel decisions.                                                        
               Petitioner did not have a strong managerial infrastructure             
          other than Ginger.  Ginger effectively performed the roles of               
          chief executive officer, chief financial officer, chief                     
          operations/administrative officer, and marketing executive.                 
          Ginger's compensation should reflect the combined salaries of the           






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