46 This means that of the total $1,571,315 that Alondra deducted for wages, we uphold respondent's disallowance to the extent of $45,700 and uphold Alondra's deduction of the remaining $1,525,615. This $1,525,615 includes both the $838,448 that we have just calculated, and the initially unchallenged figure of $687,167, which was presumably paid to Alondra's own employees. The $45,700 we disallow represents the part of Alondra's claimed deduction for wages and salaries that we are not satisfied was used by either Alondra or Pertinax to pay reasonable compensation. Our results to this point may be tabulated as follows: Deductions Allowed Allowed Disallowed Claimed Stat. Notice Tax Ct. Tax Ct. Rents (Issue 2) Alondra $225,203 $198,322 $198,322 $26,881 Edco 7,200 3,479 3,479 3,721 Pertinax 12,834 9,698 9,698 3,136 Management Services/Other (Issues 4, 3) Alondra 1,239,596 332,717 332,717 906,879 Edco 9,922 0 0 9,922 Pertinax 2,603,623 2,103,623 2,103,623 500,000 Wages & Salaries (Issues 5, 3) Alondra 1,571,315 687,167 1,525,615 45,700 Edco 35,671 0 35,671 0 Pertinax 1,655,942 1,298,653 1,455,830 200,112 It should be noted that, although we have disallowed $700,112 in deductions claimed by Pertinax in the last two categories as representing the unreasonable part of Mr. Munro'sPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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