Brewer Quality Homes, Inc. - Page 67

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          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.               








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