Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 34

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               The cases contain lengthy lists of factors that bear on the            
          determination of reasonableness.  The Court of Appeals for the              
          Ninth Circuit, to which appeal in these cases would lie, uses the           
          five-factor test of Elliotts, Inc. v. Commissioner, 716 F.2d                
          1241, 1245-1248 (9th Cir. 1983), revg. and remanding T.C. Memo.             
          1980-282.  These five factors are:  (a) Role in company; (b)                
          external comparison; (c) character and condition of company; (d)            
          conflict of interest; and (e) internal consistency.  Id.; L & B             
          Pipe & Supply Co. v. Commissioner, T.C. Memo. 1994-187; Curtis v.           
          Commissioner, T.C. Memo. 1994-15.  No single factor is                      
          controlling.  Pacific Grains, Inc. v. Commissioner, 399 F.2d 603,           
          606 (9th Cir. 1968), affg. T.C. Memo. 1967-7.                               
               (a) Role in Company                                                    
               Relevant considerations include the position held by the               
          employee, hours worked, duties performed, and the general                   
          importance of the employee to the success of the enterprise.  If            
          the employee has received a large salary increase, it may be                
          helpful to compare past and present duties and salary payments.             
          Elliotts, Inc. v. Commissioner, supra at 1245.  Even though                 
          respondent now disputes that Mr. Munro was chief executive                  
          officer of petitioners, including Pertinax, both parties have               
          treated him as such, and the record is replete with evidence that           
          he was ultimately responsible for petitioners' policy decisions.            
          Although Mr. Munro had been responsible for obtaining favorable             
          terms with suppliers in prior years, nothing in the record                  




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