- 8 - II. The Elliott Factors Applied to Petitioner’s Compensation of Mr. Reeves 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. Elliotts, Inc. v. Commissioner, supra at 1245. Mr. Reeves served as petitioner’s president, secretary, and treasurer and handled all petitioner’s managerial duties. However, the record does not establish the specific amount of time Mr. Reeves spent operating petitioner after it was incorporated. Instead, the record indicates that Mr. Reeves spent a considerable amount of his time operating petitioner’s sister corporation, VVI. B. External Comparison This factor compares the employee’s compensation with that paid by similar companies for similar services. Elliotts, Inc. v. Commissioner, supra at 1246; see sec. 1.162-7(b)(3), Income Tax Regs. Petitioner failed to provide any data comparing the compensation paid to Mr. Reeves with that paid by similar companies providing similar services. Only respondent offered expert testimony. However, respondent’s expert, Scott D. Hakala, provided a reasonable compensation analysis focusing only onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007