Brewer Quality Homes, Inc. - Page 23

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          services would be worth under that offer.  (Petitioner contends             
          that one offer would justify a 1996 compensation level higher               
          than petitioner paid, while respondent contends that, using the             
          same methodology that petitioner used, one of the other offers,             
          would lead to a conclusion that the maximum 1996 reasonable                 
          compensation would be only $79,103.)  Also, the parties do not              
          assist us in deciding how to adjust for the difference in time              
          between the offers’ presentations and the years in issue.                   
          Finally, we do not even know when one of the offers was made.               
          Under these circumstances, we conclude that the offers are not to           
          be given any weight in determining the amounts of reasonable                
          compensation for Jack’s services for the years in issue.                    
               The following indicia of relatively high reasonable                    
          compensation are present in the instant case:                               
               (1) Jack has been involved in every aspect of petitioner               
          since its inception.  Through his enthusiasm, hard work, and                
          dedication, he built petitioner into a successful enterprise.  He           
          served as its president, chairman, chief executive officer,                 
          general manager, chief financial officer, credit manager,                   
          purchasing officer, personnel manager, advertising manager,                 
          insurance agent, real estate manager, and corporate legal affairs           
          liaison.  He worked 60 hours per week, 6 to 7 days per week.                









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