- 60 - C. Reasonable Compensation to Mr. Wechsler 1. Introduction We believe that an appropriate method for reasonably compensating Mr. Wechsler for each of the years in issue should be based upon his receiving (1) an annual salary and (2) an annual bonus that is closely tied to petitioner’s earnings and profitability for that year. We reach that conclusion because we are persuaded by respondent’s expert (Mr. Hakala) of the appropriateness of that method. We are not persuaded by the approach of either of petitioner’s experts. Our reasons follow. 2. Expert Testimony a. Petitioner’s Experts i. Mr. Matthews We give little if any weight to Mr. Matthews’s opinion concerning the reasonableness of the compensation petitioner paid Mr. Wechsler for the years in issue to the extent it is based on his comparisons between petitioner and the 27 broker-dealers he examined. We are persuaded by Mr. Dorf that Mr. Matthews’s approach in drawing an analogy between petitioner and the 27 broker-dealers is unreliable because of the disparity in size between petitioner and those companies. See B & D Founds., Inc. v. Commissioner, T.C. Memo. 2001-262 n.25 (rejecting expert’s assumption that same mathematical relationship, calculated through regression analysis, between various surveyed companies’Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Next
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