- 46 - 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.Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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