- 32 - the fair after-tax return from year to year, representing the increase in theoretical retained earnings from October 31, 1985 through 1996, if a fair return was earned in each year through 1996 but no dividends were paid. Mr. Reilly then added the actual executive compensation paid to income before taxes in order to calculate the amount available to pay a fair return on invested capital and compensation to officers. Mr. Reilly used the income and executive compensation reported on petitioner's Forms 1120. He then subtracted from this subtotal a fair return on the stockholders' invested capital. Under Mr. Reilly's analysis, the remainder (residual) represents the amount available to pay the company's officers as compensation for the results of their managerial efforts. Mr. Reilly then calculated the difference between the amount available to pay petitioner's officers and the actual officers' compensation, which, in his opinion, represented the undercompensation or overcompensation in each year. Mr. Reilly calculated the amount of undercompensation or overcompensation for the taxable years ending October 31, 1987 through 1996, as follows:Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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