- 31 -
received the amounts of salaries he received. Beatrice, Betsy,
and Ben received salaries from only one or two of the Sley
Corporations, so that, as to any one shareholder or one
corporation, the salaries were grossly disproportionate to the
shareholdings. However, the aggregate salaries of each of them
were closely proportionate to their respective aggregate
ownerships of the Sley Corporations.
Betsy and Ben learned the amounts of their Sley Corporations
salaries from petitioner; they did not direct petitioner on this
matter. Petitioner set Betsy’s and Ben’s Sley Corporations
salaries, at least up to early 1986.
Table 3 shows the amounts that Markette withheld as Social
Security taxes, hereinafter sometimes referred to as F.I.C.A.
taxes, from the amounts Markette paid as salary to Betsy.
Table 3
Year Amount
1983 $2,391.91
1984 2,532.59
1985 2,791.78
1986 3,003.00
1987 3,131.70
1988 3,379.50
At the end of each year, Berger came into the Sley
Corporations’ office to calculate the amounts of the dividends
7(...continued)
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