Live preview — download the board-ready PDF to attach to your minutes.Download the free PDF

PeerBasis

Compensation Comparability Determination

Tucson Ministries Inc

Executive Director / CEO

EIN 475239406
CO · NTEE L20
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Kuhl Brown, Executive Director / CEO ($35,660) against every comparable organization that fit the selection criteria — 6 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 67^th percentile of comparable organizationswithin the typical range

How comparable organizations were selected

SectorOrganizations sharing the subject's NTEE classification (L20).
BudgetTotal revenue between $553 and $1,239 — 0.67× to 1.50× the subject's $826 (the band tightens as size grows).
GeographySame NTEE major group (L), nationwide + budget 0.67–1.5× revenue.

6 organizations qualified on sector, size, and geography → 6 within the band form the benchmarked peer set.

Distribution of comparable compensation

$4,09910th

$10,11925th

$29,734Median

$54,42475th

$62,29990th

$35,660This org · 67th

p10$4,099

p25$10,119

p50$29,734

p75$54,424

p90$62,299

$35,660

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 CO cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

Organization	State	Total revenue	Total comp	Source
Homefull Hfj Llc	OH	$912	$4,882	990
United Mutual Corp	NY	$711	$33,640	990
Aberdeen Ridge Inc	KS	$675	$25,828	990
Florence Rhf Housing Inc	CA	$612	$61,352	990
Aguila Inc	NY	$1,162	$63,245	990
Communities Empowering People Together	GA	$1,200	$3,316	990

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 CO 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

Peer count6 organizations — below 15; treat the percentiles as indicative, not precise. Compensation range $3,316–$63,245; filing years 2023–2025.
Size basisMatched on total revenue ($826); for reference, expenses $4,102 and assets $47. Revenue and expenses diverge this year — revenue may misrepresent operating size; weigh the expense-based view.
Role matchKuhl Brown, reported title "VICE PRESIDENT", benchmarked as Executive Director / CEO. Selected as the organization's highest-paid individual without an exact title match — the board should confirm this is a comparable role.
Related-org pay5 peers report related-organization compensation (column E), which the D + F benchmark does not fully capture; review where material.

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

Basis	Subject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default	67^th
Total compensation (D + F), as reported (no adjustments)	50^th
Reportable pay only (column D), adjusted	0^th
All sources (D + E + F), adjusted	50^th

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

The compensation of the Executive Director / CEO (Kuhl Brown) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
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 6 similarly situated organizations (Same NTEE major group (L), nationwide + budget 0.67–1.5× revenue).
The authorized body determined that total compensation of $35,660 is reasonable (approximately the 67^th 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). 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.