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PeerBasis
Compensation Comparability Determination

Wings Over Memphis Inc

Executive Director / CEO

EIN 474689596
TN · NTEE T12
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Paul J Gagliano, Executive Director / CEO ($4,155) against every comparable organization that fit the selection criteria — 22 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 14th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Paul J Gagliano — reported title “PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

22 organizations qualified on sector, size, and geography 22 within the band form the benchmarked peer set.

Distribution of comparable compensation

$821 total compensation of comparable organizations → $130,398 $4,155
$2,96210th
$5,16225th
$27,585Median
$41,02575th
$53,00090th
$4,155This org · 14th
p10$2,962
p25$5,162
p50$27,585
p75$41,025
p90$53,000
$4,155

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 TN 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
De Nosotros Foundation Inc MA$8,745 President $5,610 $4,796 2023
Dan River Non-profit Network VA$8,575 Executive Director $62,965 $57,838 2023
Model Transitions Foundation CA$8,273 President/ceo (Started 11/14/22) $3,439 $2,825 2023
Community Vision Inc DC$9,218 President $21,263 $17,242 2024
The Howard Fund TN$8,089 President - Comm. Fndn. Gr. Chatt. $32,548 $31,614 2024
Howe Family Foundation KS$9,293 President, Ceo, & Secretary $6,270 $6,259 2024
Otis Wilson Charitable Association IL$9,311 President $4,767 $4,459 2023
Allen A Bailey Endowment NC$9,405 Exec Dir - N $1,688 $1,659 2023
Huhlein Memorial Trust MI$9,758 Co-trustee $4,401 $4,198 2024
Community Foundation Real Estate NC$9,804 Vp & Secretary $29,355 $28,856 2023
Kay Andrews Educational Foundation FL$7,340 Officer $55,000 $51,170 2022
Scholnick Family Foundation OH$10,098 Treasurer $40,331 $40,639 2023
Afc Public Foundation AZ$7,056 President $924 $821 2024
Ccf Real Estate Holdings 2 CA$7,022 President $66,677 $53,203 2024
Faulkner University Foundation AL$6,900 President $48,780 $50,135 2023
Linda And G Arnold Kaufman MD$6,819 President & Public Dir. Until 07/24 $30,197 $26,088 2024
The Molly Lawson Foundation Inc AZ$6,768 Secretary & Treasurer (Thru 12/23) (Non-voting) $29,610 $26,314 2024
Goodman Supporting Foundation IL$10,653 Vice President & Treasurer $143,538 $130,398 2024
The Judith And Michael Berman Foundation MN$10,747 Director $38,377 $36,076 2023
Albert L Schultz & Janet A Schultz CA$5,884 Assistant Treasurer (From 5/30/24) $50,736 $40,483 2024
Joel H & Lorraine Shapiro Family MI$12,426 Treasurer $26,189 $24,979 2024
Linder Pine Supporting Org GA$12,936 Trustee $43,022 $41,153 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to TN cost of living and 2023 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 TN 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 default14th
Total compensation (D + F), as reported (no adjustments)14th
Reportable pay only (column D), adjusted82nd
All sources (D + E + F), adjusted0th

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 (Paul J Gagliano) 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 22 similarly situated organizations (Same NTEE major group (T), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $4,155 is reasonable (approximately the 14th 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.