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FY 1993 FY 1994
75th 90th 75th 90th
Percentile Percentile Percentile Percentile
1. Base salary $457,700 $735,600 $476,400 $765,700
2. Total annual comp. 554,500 866,300 577,200 901,700
3. Annual bonus comp. 96,800 130,700 100,800 136,000
(line 2-line 1)
4. Long-term incentive 549,240 882,720 571,680 918,840
comp. (line 1 x 1.2)
5. Total market-based1,103,740 1,749,020 1,148,880 1,820,540
comp. (lines 2+4)
Finally, petitioner's expert concluded that compensation between
the 75th and 90th percentiles is appropriate for an executive of
Mr. Heitz’ accomplishments, success, and leadership.
We do not accept certain aspects of petitioner's expert's
approach. His aggregation approach would result in compensation
equal to that of four full-time corporate executives. We have
not approved of aggregating salaries for an officer performing
multiple roles where each of the four salaries represents full-
time performance. Pepsi-Cola Bottling Co., Inc. v. Commissioner,
61 T.C. 564, 569 (1974), affd. 528 F.2d 176 (10th Cir. 1975);
Richlands Med. Association v. Commissioner, T.C. Memo. 1990-660,
affd. without published opinion 953 F.2d 639 (4th Cir. 1992); Ken
Miller Supply, Inc. v. Commissioner, T.C. Memo. 1978-228.
Although Mr. Heitz may have performed some of the functions of
those four executives, he most assuredly did not perform full-
time services in each of the four disciplines. Mr. Heitz’
inability to perform the services of four executives is
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