Wechsler & Co., Inc. - Page 35

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          Mr. Matthews concluded that the average 60.2 percent of its net             
          revenues that petitioner paid in aggregate compensation from 1992           
          through 1998 was reasonable, since it was virtually equal to the            
          average of 60.1 percent of net revenues paid in aggregate                   
          compensation computed for the 27 broker-dealers he examined.  He            
          further observed that the average 68.9 percent of its pretax                
          income before aggregate compensation that petitioner paid in                
          compensation from 1992 through 1998 was well below the mean or              
          group average of 84.1 percent of pretax income before aggregate             
          compensation paid in compensation computed for those 27 broker-             
          dealers.  He stated that those results indicate that petitioner             
          (1) retained a higher portion of its “discretionary income”                 
          (i.e., pretax income before compensation) and (2) paid a lower              
          portion of its “discretionary income” as compensation than did              
          most of the publicly traded broker-dealers.  Mr. Matthews added             
          that, in his experience, smaller broker-dealers with a limited              
          range of activities, like petitioner, would pay a larger                    
          percentage of their revenues to senior management employees than            
          would larger, more diversified broker-dealers.                              
               Mr. Matthews noted that, for petitioner’s 1992 through 1999            
          fiscal years, Mr. Wechsler’s annual compensation represented the            
          following percentages of the aggregate annual compensation                  
          petitioner paid to all its employees:                                       








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