- 39 - percentages method he employed for its other fiscal years could not be used for 1999, and that it was necessary to consider the “absolute numbers”. He noted that Mr. Wechsler was paid $1,494,771 in 1999, which represented 28.6 percent of his average compensation for the prior 7 years, and that his 1999 yearend bonus of $900,000 was 22.6 percent of his average bonus for the prior 7 years. He further noted that Mr. Wechsler made several large interest-free loans to petitioner during its 1999 fiscal year. He reasoned that those loans justified a substantial portion of the $900,000 bonus Mr. Wechsler received for that year. Mr. Matthews concluded that the 1999 compensation petitioner paid Mr. Wechsler was reasonable because of those loans and Mr. Wechsler’s services in managing petitioner. Lastly, Mr. Matthews opined that the 1994 fiscal year compensation of $7.09 million petitioner paid Mr. Wechsler was unreasonable and that reasonable compensation for 1994 would have been $4 million. He noted the aggregate compensation of $10.53 million petitioner paid for 1994 represents 100.5 percent of its net revenue for that year and 122.2 percent of its pretax income before payment of compensation for that year. He further noted that, if Mr. Wechsler’s 1994 compensation had been $4 million, rather than $7.09 million, petitioner’s adjusted aggregate compensation of $7.44 million ($10.53 million, less $3.09 million) would represent 71.0 percent of its net revenue for thatPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
Last modified: May 25, 2011