- 18 - Method FYE 1995 FYE 1996 Guideline cos. CEO compensation $659,849 $755,309 Guideline cos. regression analysis 345,222 339,111 Guideline co. percent of sales 887,641 409,323 Guideline cos. net margins 2,150,000 1,500,000 Average of the methods 1,010,678 750,936 The notice of deficiency allowed petitioner to deduct $1,044,809 and $367,382 as compensation to Mr. Reeves in the fiscal years at issue, respectively. Mr. Hakala’s report concluded the maximum reasonable compensation payable to Mr. Reeves in the years at issue was $1 million and $750,000,20 respectively.21 On cross-examination, Mr. Hakala conceded he was unable to consider all the facts and circumstances needed to conduct a comprehensive analysis because his financial review was limited to petitioner’s revenue and net income from FY 1985 through FY 1994 and petitioner’s tax returns for the years at issue. He testified that additional information could have made a material impact on his conclusions.22 20 See supra note 13. 21 Mr. Hakala’s reasonable compensation determinations for the years at issue were the rounded averages of figures computed by applying the four methods to the guideline companies’ financial information. See table supra p. 18. 22 In Mr. Hakala’s report and at trial, he stated that he reserved the right to amend the report to reflect consideration of additional information.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007