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Wechsler and Gilbert, the hours they worked, and their importance
to petitioner’s business. Petitioner offered no testimony from
either Mrs. Wechsler or Gilbert. Although Mrs. Wechsler had
previously worked in the financial industry, she had not worked
outside her home from the late 1970s until July 14, 1998, when
petitioner hired her and agreed to pay her minimum annual
compensation of about $500,000. Upon being hired by petitioner,
she became petitioner’s secretary and a director. She became a
full registration/general securities representative in February
1999 and a general securities principal in June 1999. Mr.
Wechsler estimated that during petitioner's 1999 fiscal year she
devoted 70 percent of her time to office management and 30
percent to portfolio research.
The credible evidence of record is even more vague
concerning what, if any, “consulting work” Gilbert performed for
petitioner during petitioner’s 1992 and 1993 fiscal years.
Gilbert already worked full time as a lighting designer at the
Metropolitan Opera. In his testimony, Mr. Wechsler essentially
claimed that Gilbert spent an unspecified amount of time in
petitioner’s office, consulted with Mr. Wechsler on scientific
and technical matters, and was also going to help introduce Mr.
Wechsler to potential investors (ostensibly people whom Gilbert
knew from working at the Metropolitan Opera over the years) in
the hedge fund Mr. Wechsler was then contemplating establishing.
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