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and $486,329 in 1995 and $337,287 in 1986 for two officers
or more executive officers of BQH based on this information.
As to the multiple-officer concern, we are satisfied that
Ding’s approach is useful, in the absence of anything better.
Ding determined appropriate total officer compensation,
subtracted the agreed-upon compensation to Mary, and concluded
that the remainder is appropriate compensation to Jack. In the
material that Hakala cites, he assumed that, in a two-officer
arrangement, the second officer was compensated at half the rate
of the first officer, and concluded that the CEO’s compensation
was 67 percent of the total officer compensation. We agree that
Hakala’s conclusions follow, arithmetically, from his
assumptions. However, Hakala does not give us any reason to
conclude that Hakala’s “attempt to address these issues” is any
better than Ding’s approach. In the absence of any hard
information as to businesses of petitioner’s size, other than the
evidence of petitioner’s own history, we are willing to follow
Ding’s approach.
Hakala’s concern that the underlying RMA data may not be
“consistent with arm’s length practices” is the more serious
attack.
However, Hakala does not provide anything to back up the
suspicion that he voices. Also, the material to which Hakala
directs our attention does not appear to address this issue at
all. Finally, the numbers that Hakala finally commends to us
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