Menard, Inc. - Page 52

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          agreement with respect to the five companies listed above and the           
          lack of evidence establishing that the other companies are truly            
          comparable to Menards, we consider only CEO compensation paid by            
          Home Depot, Kohl’s, Lowe’s, Staples, and Target.                            
                         b.  Proxy Statements45                                       
               We disagree with petitioners’ contention that the comparison           
          group companies’ TYE 1999 proxy statements reported compensation            
          paid for TYE 1998 services.  The SEC Standard Instructions (the             
          SEC instructions) for filing proxy statements provide that “If              
          the CEO served in that capacity during any part of a fiscal year            
          with respect to which information is required, information should           
          be provided as to all of his or her compensation for the full               
          fiscal year.”  17 C.F.R. sec. 229.402(a)(4) (2004) (emphasis                
          added).  Furthermore, the SEC instructions for the proxy                    
          statement’s summary compensation table state that the table shall           
          include executive compensation “earned by the named executive               
          officer during the fiscal year covered”.  17 C.F.R. sec.                    
          229.402(b)(2)(iii) (emphasis added).  Even assuming that Mr.                
          Rowley is correct that companies do not make their decisions with           
          respect to bonuses and LTI compensation until a few months after            
          the beginning of the next fiscal year, the bonuses and LTI                  


               45In the past, we have permitted the use of SEC proxy                  
          statement data for the comparison of an executive’s compensation            
          to comparable companies’ executives’ compensation.  See Square D            
          Co. & Subs. v. Commissioner, 121 T.C. 168 (2003).                           




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