Menard, Inc. - Page 17

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          Depot, Kohl’s, Lowe’s, Staples, and Target.  For services                   
          performed in TYE 1998, the comparison group companies paid                  
          compensation to their CEOs as follows:                                      
                          Company            Compensation                             
                         Home Depot          $2,841,307                               
                         Kohl’s              5,110,578                                
                         Lowe’s              6,054,977                                
                         Staples             6,868,747                                
                         Target              10,479,528                               
               B.  Rate of Return on Investment                                       
               For TYE 1998, the comparison group companies’ and Menards’s            
          rates of return on equity12 were as follows:                                
                          Company            Return on Equity                         
                         Menards                  18.8%                               
                         Home Depot               16.1                                
                         Kohl’s                   14.8                                
                         Lowe’s                   13.7                                
                         Staples                  15.3                                
                         Target                   16.7                                
          III.  Mr. Menard                                                            
               Mr. Menard is a cash basis taxpayer with a taxable year                
          ending December 31.  Between March 30 and April 15, 1999, Mr.               
          Menard timely filed Form 1040, U.S. Individual Income Tax Return,           
          for 1998.                                                                   
               A.  Mr. Menard’s Duties and Responsibilities at Menards                
               Since he founded the company, Mr. Menard has been involved             
          in Menards’s daily business affairs.  During TYE 1998, Mr. Menard           


               12As calculated herein, return on equity equals net income             
          divided by shareholders’ equity and multiplied by 100 percent.              




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