Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 46

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          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's             




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