- 67 - amount Hakala would say would be reasonable compensation. We find it difficult to justify an analysis that leads to such a counterintuitive result. Under these circumstances, we conclude that (1) Hakala’s application of CAPM on the record herein presents too many difficulties to justify using CAPM in the calculation of reasonable compensation for Jack, and (2) neither Hakala nor Sledge has explained CAPM sufficiently for us to be able to determine what would be the bottom-line effect of even correcting the arithmetic errors we have described, except that we perceive it is more likely than not that those corrections would produce reasonable compensation numbers somewhat greater than those that Hakala recommended. However, it appears from respondent’s reactions on brief that respondent is willing to accept Hakala’s recommendations even when the amounts exceed what had been determined in the notice of deficiency. Accordingly, we conclude: (1) Based on the foregoing analysis of Hakala’s independent investor approach and the correction of Hakala’s arithmetic errors (plus the allowance for Jack’s loan guaranty), 1995 reasonable compensation for Jack’s services is $610,000; and (2) based on the foregoing analysis of the RMA data (plus an amount for nonsalary benefits), 1996 reasonable compensation for Jack’s services is $630,000.Page: Previous 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 Next
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