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this added risk, which it likens to "combat-pay." Although
petitioner's other employees also travel abroad and transport
jewels throughout the city of Atlanta, they are not given
"combat-pay." Petitioner does not employ a security guard on its
premises.
Petitioner's Salary Policy
During 1991 and 1992, Mr. Haviv determined the salaries,
commissions, and bonuses for all of petitioner's employees.
Salaries were fixed for the entire year. Salespersons earned
commissions of 50 percent of gross profits on all sales made to
their personal customers. When a sale was made to a "house
customer" salespersons would typically earn commissions of 5
percent of the gross sale.5 All "house customers" were
considered to be customers of Mr. Haviv, although he was not
bound by the commission structure. Petitioner had no written
policy for bonuses.
A Comparison of Salaries Paid to Mr. Haviv with Gross
Income and Net Income
In 1991, Mr. Haviv's compensation was four times larger than
his average compensation from the prior 3 years. In 1992, his
total compensation exceeded that of 1991. For 1988-92 petitioner
paid Mr. Haviv the following percentages of gross revenues:
5 "House customers" are those customers who do not seek
an individual salesperson. Since Ms. Leamon did not receive 5
percent of the red diamond sale price, we are at a loss to
understand how this rule was applied.
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