Herold Marketing Associates, Inc. - Page 1

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                                  T.C. Memo. 1999-26                                   


                               UNITED STATES TAX COURT                                 


                  HEROLD MARKETING ASSOCIATES, INC., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       


               Docket No. 1529-97.                  Filed January 29, 1999.            


                    Held:  Compensation paid by P to its sole                          
               shareholder/CEO was reasonable.                                         

               Daniel J. Boivin, Frank R. Berman, and Jeffrey A. Olson,                
          for petitioner.                                                              
               Jack M. Forsberg, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                         

               LARO, Judge:  Herold Marketing Associates, Inc., petitioned             
          the Court to redetermine 1992 and 1993 income tax deficiencies of            
          $246,508 and $247,829, respectively.  The deficiencies stem from             
          respondent's determination that $700,000 of the $1.2 million in