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's
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