- 23 - familiarity with general business matters and with office and administrative support functions, having previously worked as a computer programmer and stockbroker. After joining Mr. Myers in managing petitioner, she obtained a bachelor’s degree in business in 1990. This factor favors petitioner with respect to Mr. Myers but is neutral with respect to Mrs. Myers. B. The Nature, Extent, and Scope of Mr. and Mrs. Myers’s Work An employee’s position, hours worked, duties performed, and general importance to the success of the business may justify high compensation. Home Interiors & Gifts, Inc. v. Commissioner, supra at 1158. Mr. Myers was petitioner’s key employee and driving force from its inception, and his personal services were essential to its success. He managed and built up petitioner’s business, solicited and obtained all petitioner’s jobs, and supervised and was responsible for all work performed. On brief, respondent argues that, by the year ended July 31, 1996, Mr. Myers had substantially reduced the hours per week he worked for petitioner, and was devoting a substantial percentage of his time to the businesses of Myers Foundations and Collins Concrete. In doing so, respondent relies heavily on a tax return filed for the same period by Myers Foundations, the foundation and flat work construction company that Mr. Myers and his sonPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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