Guy Schoenecker, Inc., Business Incentives, Inc., and Carousel By Guy, Inc. - Page 23

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            for its fiscal year 1989, $296,816 for its fiscal year 1990, and                               
            $338,475 for its fiscal year 1991.  Accordingly, respondent                                    
            disallowed the balance of the compensation claimed to be                                       
            deductible by GSI and subsidiaries for Mr. Schoenecker in each of                              
            these years.                                                                                   
                                                 OPINION                                                   
                 Section 162(a)(1) allows as a deduction a reasonable                                      
            allowance for salaries or other compensation paid for personal                                 
            services rendered.  In order to be deductible, the amount must be                              
            paid for services rendered and not a substitute for dividends,                                 
            and must be reasonable for the services rendered.  Charles                                     
            Schneider & Co. v. Commissioner, 500 F.2d 148, 152 (8th Cir.                                   
            1974), affg. T.C. Memo. 1973-130.  The Schneider case, citing                                  
            Mayson Manufacturing Co. v. Commissioner, 178 F.2d 115, 119 (6th                               
            Cir. 1949), lists the following factors that are often considered                              
            in determining the reasonableness of compensation:  (1) The                                    
            employee's qualifications; (2) the nature, extent, and scope of                                
            the employee's work; (3) the size and complexities of the                                      
            business; (4) a comparison of salaries paid with the employer's                                
            gross income and net income; (5) the prevailing general economic                               
            conditions; (6) a comparison of salaries with distributions to                                 
            stockholders; (7) the prevailing rates of compensation for                                     
            comparable positions in comparable concerns; (8) the salary                                    
            policy of the taxpayer as to all employees; and (9) in the case                                
            of small corporations with a limited number of officers, the                                   



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