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Nothing in the record gives us comfort that treating blank
responses as negative responses is a reasonable approach under
the circumstances. Once again, "'We are not satisfied that a
reasonable level of compensation for an executive like * * *
[Herold] can be accurately determined by reference to the
industries * * * [Mr. Carey] surveyed because of the absence of
significant information on other businesses similar to
petitioner's.'" Pulsar Components Intl., Inc. v. Commissioner,
T.C. Memo. 1996-129 (quoting Thomas A. Curtis, M.D., Inc. v.
Commissioner, T.C. Memo. 1994-15); see also Mad Auto Wrecking,
Inc. v. Commissioner, T.C. Memo. 1995-153. Indeed, comparing
compensation paid to officers of companies that differ markedly
provides guidance of dubious value. See Diverse Indus., Inc. v.
Commissioner, T.C. Memo. 1986-84; Niagara Falls Coach Lines, Inc.
v. Commissioner, T.C. Memo. 1977-269.
8. Employer's Salary Policy As to All Employees
Courts have considered salaries paid to other employees of a
business in deciding whether compensation is reasonable.
Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. at 1159.
We look to this factor to determine whether Herold was
compensated differently than petitioner's other employees merely
because of Herold's status as a shareholder. Owensby & Kritikos,
Inc. v. Commissioner, 819 F.2d at 1322-1323. A reasonable,
longstanding, and consistently applied compensation plan is
evidence that compensation is reasonable.
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