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Their families, including the children, were also involved in the
personal relationship.
During the years in issue, Marvin K. Sullivan was the
corporation’s chief operating officer, and procedures were in
place for evaluating employee compensation. Each department head
would evaluate the employees under him and send his evaluations
of them, along with salary and bonus recommendations to Mr.
Sullivan. He would then meet with Drs. Deland and Noell to
discuss salary and bonus adjustments for the corporation’s
employees. Mr. Sullivan personally supervised petitioner and
evaluated her performance in the same manner as other employees
of the corporation. Mr. Sullivan considered petitioner to be one
of the “finest clinical therapists in the country”. Mr. Sullivan
evaluated petitioner’s performance for 1993, 1994, and 1995, and
he recommended the amounts of her bonuses for those years, which
were approved by Drs. Deland and Noell.
Petitioner received the following annual salary and bonuses
for 1989 through 1995:
Year Salary Bonus Total
1989 $38,000.00 $1,000 $39,000.00
1990 41,800.00 1,750 43,550.00
1991 47,500.00 2,500 50,000.00
1992 51,100.00 11,000 62,100.00
1993 56,292.61 25,000 81,292.61
1994 59,242.70 35,000 94,242.70
1995 62,856.81 35,000 97,856.81
With respect to 1993, 1994, and 1995, petitioner received Forms
W-2, Wage and Tax Statement, from the corporation that reflected
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