26
376, 418 (1989), affd. 920 F.2d 1196 (5th Cir. 1990); Markwardt
v. Commissioner, 64 T.C. 989, 997 (1975). In what follows, we
consider Alondra and Edco wage expense deductions only insofar as
they were either actually or allegedly paid to Pertinax as
reimbursement for wages paid by Pertinax to its employees.
The record suggests but does not state that corporate
petitioners paid fees for management services only to Pertinax.
If any such fees were paid to other parties, substantiation of
such payments would also be a matter not before the Court. In
any event, insofar as payments by Alondra to Pertinax for
management services, and to Mr. Munro for rent, require
substantiation, we find that they have been substantiated in the
record, regardless of which party is deemed to have the burden of
proof. Accordingly, we deny as moot corporate petitioners'
motion to shift the burden to respondent with respect to wage and
salary payments by Alondra.
For Edco, respondent disallowed all deductions for wages and
management services in her statutory notice. Respondent admits
that, of the total claimed deductions for management services and
management wages of $45,593, petitioner Edco has substantiated
payments of $37,657.64. We need only consider who has the burden
of substantiating payment of the remaining $7,935.36 if we decide
infra that reasonable payment by Edco to Pertinax exceeded
$37,657.64. Inasmuch as we do not so find, there is no need for
further substantiation of payment of any of Edco's claimed
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