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We start with Dorf’s data for the average CEO (i.e.,
$211,324 in 1993 and $231,538 in 1994) to decide the
reasonableness of Steven Klein’s compensation, but we do not
increase it based on compensation paid to a person with research
and development skills because he lacked Isidore Klein’s skills
in that area. However, due to Steven Klein’s long hours worked,
we think Dorf’s data suggests the maximum amount of reasonable
compensation for Steven Klein would be $300,000 for 1993 and
$300,000 for 1994.
b. Hakala
Hakala testified that the most a similar company would have
reasonably paid for the combined services of Isidore and Steven
Klein was $405,250 in 1993 and $392,157 in 1994. He also
testified that the most a similar company would have reasonably
paid Steven Klein in 1995 was $439,284. We believe that he
underestimated the total amount Isidore and Steven Klein could
reasonably be paid in 1993 and 1994 but that his estimate of
Steven Klein’s reasonable compensation for 1995 was correct.
Petitioner argues that Hakala relied on companies that were
not comparable to petitioner. We disagree. Although Hakala
considered Conference Board surveys of larger, public companies,
he primarily focused on data from companies that specialized in
fabricating metal products and that had annual sales comparable
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