- 3 - Petitioner is a closely held corporation, the principal place of business of which was in Ohio when it filed its petition. The primary issue in the underlying case, Boca Constr., Inc. v. Commissioner, T.C. Memo. 1995-5, filed January 9, 1995, was whether petitioner may deduct as reasonable compensation amounts it paid to its officers in the years in issue. Petitioner deducted as compensation for its officers $689,600 for 1989 and $817,500 for 1990. Respondent's revenue agent examined petitioner's return and investigated this case. Respondent determined that the amount of compensation petitioner paid to its officers in the years in issue was unreasonable. Respondent relied on facts obtained by the revenue agent and reports from Robert Morris Associates (RMA) and the Occupational Outlook Handbook to determine reasonable compensation. In the notice of deficiency, the answer, at trial, and on brief, respondent's position was that reasonable compensation for petitioner's officers was $274,000 in 1989 and $282,000 in 1990. Respondent did not call any witnesses at trial. We held that the compensation petitioner paid to its officers was reasonable.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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