- 29 - $191,652 and $315,500 for 1996. We do not accept certain aspects of Mr. Reilly's analysis. Mr. Reilly's aggregation approach would result in compensation equal to that of four full-time corporate executives. We reject Mr. Reilly's suggestion that Dennis performed the work of four full-time executives serving as petitioner's president and CEO, chief financial officer, vice president of marketing and sales, and COO. Although Dennis may have performed some of the duties and functions of four such executives, he did not perform work equal to the full-time services of four such executives. Although the more roles or functions an employee performs the more valuable his services are likely to be, an employee who performs four jobs, each on a part-time basis, is not necessarily worth as much to a company as four employees each working full time at one of those jobs. Dennis testified that he worked 80 to 90 hours per week. Four full-time employees would have worked at least 160 combined hours each week. It is therefore inappropriate to aggregate the normal full-time salary for four jobs to compute the reasonable compensation of the employee who fills all four of them. See Pepsi-Cola Bottling Co. v. Commissioner, 61 T.C. 564, 569 (1974), affd. 528 F.2d 176 (10th Cir. 1975); Richlands Med. Association v. Commissioner, T.C. Memo. 1990-660, affd. without published opinion 953 F.2d 639 (4th Cir. 1992); Ken Miller Supply, Inc. v. Commissioner, T.C. Memo. 1978-228.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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