- 16 -
must prove it wrong. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933); RTS Inv. Corp. v. Commissioner, supra at 650.
Factors to consider in passing on the question of reasonableness,
no one factor of which is controlling in itself, include:
(1) The employee's qualifications; (2) the nature, extent, and
scope of the employee's work; (3) the size and complexities of
the employer's business; (4) a comparison of salaries paid with
the employer's gross and net income; (5) the prevailing general
economic conditions; (6) a comparison of salaries with
distributions to officers and retained earnings; (7) the
prevailing rates of compensation for comparable positions in
comparable concerns; (8) the salary policy of the employer as to
all employees; (9) the amount of compensation paid to the
particular employee in previous years; (10) the employer's
financial condition; (11) whether the employer and the employee
dealt at arm's length; (12) whether the employee guaranteed the
employer's debt; (13) whether the employer offered a pension plan
or profit-sharing plan to its employees; and (14) whether the
employee was reimbursed by the employer for business expenses
that the employee paid personally. See Rutter v. Commissioner,
853 F.2d 1267, 1274 (5th Cir. 1988), affg. T.C. Memo. 1986-407;
Charles Schneider & Co. v. Commissioner, supra at 151-152; Estate
of Wallace v. Commissioner, supra at 553; Home Interiors & Gifts,
Inc. v. Commissioner, 73 T.C. 1142, 1155-1156 (1980); see also
Mad Auto Wrecking, Inc. v. Commissioner, supra.
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