Wechsler & Co., Inc. - Page 66

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         from the broker-dealers Mr. Matthews identified.  Though                     
         petitioner’s endeavors covered a range of activities during the              
         relevant period, proprietary trading was responsible for most of             
         its revenue, and commissions generated only a small percentage.              
         (According to the report of petitioner’s expert, Mr. Dorf, during            
         the audit period petitioner reaped only 0.4 percent of its income            
         from commissions, whereas most of its income came from its                   
         investments.)                                                                
              Because petitioner carried on a unique mix of investment                
         services and trading operations, it would be difficult, if not               
         impossible, to neatly classify its business.  Rather, at best,               
         petitioner could be described only as a business offering a                  
         unique combination of financial services and investments.  Thus,             
         in determining reasonable incentive compensation for Mr.                     
         Wechsler, we are unable to look to the compensation practices of             
         any single business or any single type of business for guidance.             
         Rather, we must look more generally to compensation practices in             
         the investment industry.                                                     
              As a basis for determining reasonable incentive compensation            
         for Mr. Wechsler, we therefore adopt Mr. Hakala’s percentage-of-             
         profits approach, which he argues is customary in the investment             
         industry.  According to Mr. Hakala’s calculations, an independent            
         investor in petitioner would have received a reasonable return on            
         equity had petitioner’s incentive compensation been limited to 20            






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