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Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
Some of the issues raised by the pleadings have been
disposed of by agreement of the parties, leaving for our decision
whether the deduction claimed by Guy Schoenecker, Inc., and
subsidiaries (petitioner) for compensation to Guy Schoenecker
(Mr. Schoenecker) exceeds reasonable compensation for services
rendered by Mr. Schoenecker and, if so, the proper deduction for
compensation to Mr. Schoenecker in each of the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
Guy Schoenecker, Inc. (hereinafter GSI), is a corporation
formed on November 9, 1978, with its principal place of business
in Minneapolis, Minnesota. During the years here in issue 99
percent of the stock of GSI was owned by Mr. Schoenecker and
certain family trusts, and 1 percent was owned by his son, Larry
Schoenecker (Larry). GSI owns and has owned since its inception
100 percent of the stock of Business Incentives, Inc. (BI). GSI
also owns and has owned since its inception 100 percent of the
stock of Carousel By Guy, Inc. (formerly Animal Fair, Inc., and
hereinafter referred to as Animal Fair). GSI and its
subsidiaries kept their books and reported their income on an
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Last modified: May 25, 2011