Normandie Metal Fabricators, Inc. - Page 34

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          in size to petitioner’s (that is, between $2 and $5 million).               
               Petitioner contends that Hakala failed to consider that                
          petitioner and the services of Isidore Klein and Steven Klein are           
          unique.  Although all companies and corporate officers are in one           
          sense unique, we believe that survey data cited by Hakala (as               
          well as Dorf) is helpful in deciding the amount of Isidore and              
          Steven Klein’s reasonable compensation.                                     
               Hakala concluded that, from the standpoint of a hypothetical           
          independent investor, the compensation petitioner paid to Isidore           
          and Steven Klein in 1993 and 1994, and to Steven Klein in 1995,             
          was unreasonable.  Hakala pointed out that, although petitioner             
          was very profitable before paying officers’ compensation, its               
          performance after paying officers’ compensation was well below              
          what would satisfy an independent investor.  Hakala estimated the           
          maximum amount petitioner could pay Isidore and Steven Klein                
          while paying a reasonable return to an independent investor and             
          concluded that the compensation paid to Isidore and Steven Klein            
          was about twice the maximum reasonable compensation.                        
               Petitioner criticizes Hakala for not separately valuing the            
          services of Steven and Isidore Klein.  We agree that having a               
          separate opinion for their reasonable compensation would have               
          been more helpful, but despite that we still find Hakala’s                  
          analysis to be helpful.                                                     








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