- 56 - Menards’s performance to the comparison group companies’ performances to determine how the marketplace valued services comparable to those provided to Menards by Mr. Menard during TYE 1998 and to decide what portion of Mr. Menard’s compensation was reasonable within the marketplace. See Exacto Spring Corp. v. Commissioner, 196 F.3d at 838; sec. 1.162-7(b)(3), Income Tax Regs. Although comparisons to Kohl’s, Staples, and Target are helpful to an extent, we can more accurately gauge a reasonable amount of compensation for Mr. Menard by focusing on how Menards compared to its direct competitors in home improvement retailing, Home Depot and Lowe’s, during TYE 1998. In his report, Dr. Hakala described Home Depot and Lowe’s as “directly comparable” to Menards. Similarly, while contrasting Menards’s performance during TYE 1998 with Home Depot’s and Lowe’s performances, petitioners characterized the two companies as Menards’s “closest competitors”. In TYE 1998, Home Depot, Lowe’s, and Menards had gross revenue, revenue growth, and net income as follows:Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
Last modified: May 25, 2011