- 47 - III. Conclusion We consider respondent’s analogy of Mrs. Harrison’s activities on petitioner’s behalf to the duties performed by an outside board chair to be apposite. Moreover, Mr. Carey’s focus on the median compensation paid to outside board chairs at comparably sized companies appears reasonable in the absence of evidence that Mrs. Harrison’s services should place her in either a higher or lower percentile. We find, however, that Mrs. Harrison’s lifetime devotion to petitioner’s business, the respect for her judgment accorded by her sons who actually ran the business on a day to day basis, and her dedication in the performance of her public relations function, even at an advanced age, afforded benefits to petitioner (whether tangible or intangible) that were unlikely to have been afforded by an outside board chair. We find that the value of those additional benefits is adequately reflected by an 80-percent premium over and above the median compensation paid to an outside board chair during the audit years. Therefore, we hold that petitioner may deduct the following amounts (rounded to the nearest $1000) as compensation for services performed by Mrs. Harrison during each of the audit years: TYE 6/30 Amount 1995 $98,000 1996 101,000 1997 106,000Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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