Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 21

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          1987 for wages and management services amounting to $1,231,127.10           
          Because we do not know how much of the $225,203 claimed by                  
          Alondra as a rent deduction is supposed to have been paid to                
          third parties, we cannot determine the exact relationship of this           
          amount to the rental income that Mr. Munro reported as such in              
          his 1987 individual income tax return.  However, Mr. Munro's                
          reporting of rental income appears consistent with the rental               
          payments that petitioners claimed as deductions.                            
               Edco has documented payments of $37,658 to Pertinax during             
          Edco's fiscal 1987 for wages and management services.  Mr. Munro            
          appears to have included the $7,200 claimed by Edco as a rent               
          deduction in the rental income that he reported in his 1987                 
          individual income tax return as rental income.                              
               Pertinax, in its U.S. Partnership Return of Income for 1987,           
          reported as gross income $2,649,859 in management fees.  It                 
          deducted $1,655,942 for salaries and wages and $500,000 for                 
          "management".  Respondent, having determined that reasonable                
          compensation for Mr. Munro was $142,823, disallowed the $500,000            
          management deduction and $357,289 of the deduction for salaries             
          and wages claimed by Pertinax.                                              



          10Respondent concedes that petitioners have documented                      
          $1,198,407 through one exhibit and an additional $32,450 through            
          another pair of exhibits.  In fact, however, the first of these             
          exhibits, by our calculation, documents $1,198,677.  As a result,           
          the total documented is $1,231,127, not $1,230,857, as respondent           
          calculates.                                                                 




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