Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 39

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          compensate for the prior underpayments.  Estate of Wallace v.               
          Commissioner, 95 T.C. 525, 553-554 (1990), affd. on another                 
          ground 965 F.2d 1038 (11th Cir. 1992).                                      
               As we have seen supra note 6, earlier growth was not so                
          extraordinary.  In any case, Mr. Munro was highly compensated in            
          earlier years,18 so no reason was shown to reward him in                    
          1986-1987 for what he had done earlier.  Moreover, there is                 
          nothing in the record to indicate that any of the compensation              
          paid to Mr. Munro in 1987 was earmarked as being for prior                  
          services; the absence of any earmarking supports the view that              
          petitioners' argument in this regard is a mere afterthought.                
          Pacific Grains, Inc. v. Commissioner, 399 F.2d at 606.                      
               On balance, this factor supports upholding normal chief                
          executive officer compensation for the current year for Mr.                 
          Munro.                                                                      
               (d) Conflict of Interest                                               
               This fourth factor focuses on whether a relationship exists            
          between petitioners and the employee (here Mr. Munro) that might            
          permit them to disguise nondeductible corporate distributions of            
          income as deductible salary expenditures.  Such a relationship              
          may exist where the employee is a business's sole or controlling            


          18In 1986, the salary income reported on Mr. and Mrs.                       
          Munro's joint income tax return was $596,316.  We have no                   
          evidence for 1984 and 1985.  In 1983, Mr. Munro's salary was                
          $309,504.  In 1982, it was $231,500.  In 1979, 1980, and 1981, it           
          was $240,000.                                                               




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