-2- percent of the interest on $807,983. The deficiency is based on respondent's determination that $1,642,593 of the $1,777,800 petitioner deducted as compensation paid to its president, Richard L. Leonard, was unreasonable. Following respondent’s concession of the additions to tax, the sole issue for decision is the amount of compensation paid by petitioner that is reasonable and thus deductible as a section 162 business expense. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Except where indicated by the notation Can$ (standing for Canadian), all dollars are U.S. dollars. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time petitioner Leonard Pipeline Contractors, Ltd. filed its petition herein, its principal place of business was in Scottsdale, Arizona. Petitioner filed its 1987 Federal income tax return based on a fiscal year ending September 30, 1987. Petitioner's History Petitioner was incorporated in Canada on September 28, 1977. From its incorporation through the year in issue, petitioner engaged in pipeline construction and related activities, eitherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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