Sunbelt Clothing Company, Inc., f.k.a. Unprinted T-Shirt Warehouse, Inc. - Page 27

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                          Appropriate Compensation for Mr. Bennett                    
               Direct      Pension   Profit     Total  Actually                       
          FYE    Compensation    Plan    Sharing  Compensation    Paid     Difference 
          7/29/90   $1,146,800   $126,100   $899,900  $2,172,800  $2,030,000 $(142,800)
          7/28/91      810,000    132,400  1,292,800   2,235,200   2,030,000  (205,200)
          8/02/92    1,140,300    139,000    729,700   2,009,000   2,050,200    41,200

          Total   $3,097,100   $397,500 $2,922,400  $6,417,000  $6,110,200 $(306,800) 

                            Appropriate Compensation for Mr. Sokol                    
               Direct      Pension   Profit     Total  Actually                       
          FYE    Compensation    Plan    Sharing  Compensation    Paid     Difference 
          7/29/90     $513,400   $327,000   $300,000  $1,140,400    $670,000   $(470,400)
          7/28/91      511,400    343,300    430,900   1,285,600     670,000    (615,600)
          Total   $1,024,800   $670,300   $730,900  $2,426,000  $1,340,000 ($1,086,000)

               Although we do not rely solely on Mr. Gallagher's conclusions          
          in this regard, we do find his qualifications in the area of                
          executive compensation superior to those of Mr. Burns.  In                  
          addition, Mr. Gallagher contemplated many of the same factors               
          considered by this and other courts in developing his compensation          
          plan for Messrs. Bennett and Sokol.  Therefore, we find his                 
          conclusions regarding the reasonable compensation of Messrs.                
          Bennett and Sokol persuasive.                                               

          8.  Compensation Paid in Prior Years                                        

               An employer may deduct compensation paid to an employee in a           
          year although the employee performed the services in a prior year.          
          Lucas v. Ox Fibre Brush Co., 281 U.S. 115, 119 (1930); see also             
          R.J. Nicoll Co. v. Commissioner, 59 T.C. at 50, and the cases cited         





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