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there are very few engineers who have made careers specializing
in this area. Mr. Heitz combines his technical expertise with
the ability to identify and attract clients and to develop
springs to perform a specific function for that client. As of
the years in question, he had established a stable and highly
successful pattern of applied expertise in product innovation and
development and packaging technology. It would have been very
difficult to replace Mr. Heitz. See id.
C. Qualifications of the Employee
An employee's superior qualifications for his or her
position with the business may justify high compensation.
Edwin's, Inc. v. United States, supra at 677; Dave Fischbein
Manufacturing Co. v. Commissioner, 59 T.C. 338, 352-353 (1972).
Mr. Heitz is highly qualified to run Exacto as a result of his
education, training, experience, and motivation. Mr. Heitz has
over 40 years of highly successful experience in the field of
spring design.
D. Contribution of the Employee to the Business
The fourth factor identified by the Court of Appeals
concerns the employee's contribution to the success of the
business. An employee's substantial contribution to the
employer's success may justify a high level of compensation.
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