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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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