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Dorf estimated how much it would have been reasonable for
petitioner to pay Isidore Klein from 1975 to 1994. Dorf added
what he estimated was the compensation of a full-time chief
executive officer without Isidore Klein’s research and
development capabilities ($211,324 in 1993 and $231,538 in 1994),
to 50 percent of what he said was the compensation of a full-time
research and development professional ($187,578 in 1993 and
$153,712 in 1994). He concluded that petitioner overpaid Isidore
Klein by $46,887 in 1993 and $59,606 in 1994, but he concluded
that Isidore Klein’s compensation was reasonable in those years
in part because it was catchup pay for prior years. We rejected
Dorf’s suggestion that Isidore Klein was paid catchup pay at
paragraph II-B-1-a, above. Dorf's data suggests that
compensation paid to Isidore Klein up to $305,113 in 1993 and
$308,394 in 1994 might have been reasonable if he had worked full
time. There is no convincing evidence of how much time he
worked. We think two-thirds (or somewhat less) time would be a
reasonable estimate based on how often he called and visited
employees, the fact that he attended some trade shows and worked
on the portable housing project, and because he reviewed various
records of petitioner’s. Dorf’s data (which is based on full-
time service) suggests that compensation for Isidore Klein of
about $200,000 per year for 1993 and 1994 would be reasonable.
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