Wechsler & Co., Inc. - Page 46

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              Mr. Hakala opined that reasonable compensation for Mr.                  
         Wechsler for petitioner’s 1992 through 1999 fiscal years would be            
         as follows:                                                                  
                                                            Total                     
         FYE May 31        Base Salary        Bonus        Compensation               
         1992            $390,000         $776,768      $1,166,768                    
         1993             405,000          961,895       1,366,895                    
         1994             390,000          511,130         901,130                    
         1995             420,000        1,053,086       1,473,086                    
         1996             390,000        1,536,230       1,926,230                    
         1997             390,000            --            390,000                    
         1998             415,000          877,817       1,292,817                    
         1999             571,694            --            571,694                    
         IV.  Application of Reasonable Compensation Factors                          
              A.  Role in the Company                                                 
              This factor focuses on the employee’s importance to the                 
         success of the business.  Pertinent considerations include the               
         employee’s position, hours worked, and duties performed and the              
         general importance of the employee to the company.  Rapco, Inc.              
         v. Commissioner, 85 F.3d at 954-955; Elliotts, Inc. v.                       
         Commissioner, 716 F.2d at 1245.                                              
              Since at least as early as 1988, Mr. Wechsler has been                  
         petitioner’s key employee and the primary reason for its overall             
         success.  He has worked long hours, been intimately involved in              
         managing petitioner’s business, and closely supervised all of                
         petitioner’s investment and trading activities.                              
              In contrast to the evidence concerning Mr. Wechsler, the                
         evidence is sketchy concerning the work performed by Mrs.                    






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