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B. Compensation Paid to Other Employees
Petitioner paid Ferguson at the high end of the compensation
range. Petitioner presented no evidence that its other employees
were compensated at or near the high end of the compensation
range. Cf. Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C.
1142, 1162 (1980). This factor favors respondent.
Based on the factors outlined above, we conclude that
$650,000, $700,000, and $850,000 represent a reasonable amount of
compensation to Ferguson for petitioner's fiscal years ending
1990, 1991, and 1992, respectively.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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