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PeerBasis
Compensation Comparability Determination

Commodore Denig American Legion

Executive Director / CEO

EIN 344176085
OH · NTEE W30
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Gary Mitchell, Executive Director / CEO ($2,400) against every comparable organization that fit the selection criteria — 82 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 2nd percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Gary Mitchell — reported title “ADJUTANT”, selected as the organization's highest-paid individual — no exact title match, so confirm this is a comparable role.

How comparable organizations were selected

82 organizations qualified on sector, size, and geography 82 within the band form the benchmarked peer set.

Distribution of comparable compensation

$819 total compensation of comparable organizations → $365,693 $2,400
$11,93710th
$22,71525th
$53,754Median
$72,22075th
$96,15490th
$2,400This org · 2nd
p10$11,937
p25$22,715
p50$53,754
p75$72,220
p90$96,154
$2,400

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to OH cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
23rd Veteran MN$461,910 Executive Director $85,800 $80,045 2024
Wisconsin Veterans Network Inc WI$462,596 Executive Dir. $68,992 $68,029 2024
Skeleton Crew Adventures TX$459,641 Director Of $47,017 $45,717 2023
National Guard Association Of Sc SC$465,989 Executive Director $80,000 $78,798 2024
Take A Vet Fishing Nfp FL$466,907 President $50,000 $45,658 2023
Angel Force Usa CA$467,001 President $19,000 $15,948 2023
Navy League Of The Us-honolulu Council HI$469,792 Executive Director/national Director $96,211 $81,328 2024
Jerry Ambrose Veterans Council Of Mohave County AZ$475,017 President $2,550 $2,315 2024
Liet Harold R Cornwall Post 1298 KY$447,276 Quartermaster $6,500 $6,788 2023
The United States Armor Association GA$481,890 Executive Di $72,000 $68,352 2024
Roslyn Vfw Home Association PA$440,300 Bar Manager Board Member $39,600 $38,387 2023
Saratoga Warhorse Foundation Inc NY$439,809 Executive Di $155,357 $136,460 2023
National Memorial Of Military IL$436,890 Secretary $10,800 $10,025 2024
Returning Veterans Project OR$435,384 Executive Dir. $109,882 $96,344 2024
The Veteran's Advocacy Foundation Inc MO$489,382 President And Executive Director $57,865 $59,574 2023
American Legion Walter Graham Post 332 IL$432,360 Manager $43,428 $40,310 2024
Talons Reach Foundation Inc MT$493,351 President $18,462 $18,789 2024
American Military Family Inc CO$493,976 Founder/ceo $76,397 $69,164 2024
Veteran's Advocacy Alliance Inc VA$498,247 Vice President $70,301 $64,088 2024
Modern Warrior Live OH$503,699 Executive Vi $48,000 $48,000 2024
Friends Of Fisher House - Illinois Inc IL$419,182 President $45,000 $41,769 2024
It's About The Warriors Foundation PA$415,009 Executive Director/president/secretary $85,980 $80,953 2024
Department Of Sc Vfw Of United States SC$404,075 Service Officer $56,000 $53,737 2025
Service Dogs For Veterans SC$521,290 President $68,333 $67,307 2024
Newby-ginnings Of North Idaho Inc ID$401,878 Executive Director $52,000 $53,770 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to OH cost of living and 2024 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to OH cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default2nd
Total compensation (D + F), as reported (no adjustments)1st
Reportable pay only (column D), adjusted4th
All sources (D + E + F), adjusted2nd

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Gary Mitchell) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 82 similarly situated organizations (Same NTEE sector (W30), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $2,400 is reasonable (approximately the 2nd percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.