-30-
Mr. Leonard’s services, we are persuaded that petitioner is entitled
to a greater compensation deduction than that allowed by respondent.
Any attempt to determine reasonable compensation with
mathematical precision is impossible. See, e.g., Jones Bros. Bakery
v. United States, 188 Ct. Cl. 226, 245, 411 F.2d 1282, 1294 (1969).
Using our best judgment, we conclude that $700,000 would represent
a reasonable amount of compensation to Mr. Leonard for 1987. The
$700,000 amount represents $300,000 as a lump-sum retirement payment
and $400,000 for salary and bonus. See Pepsi-Cola Bottling Co. of
Salina, Inc. v. Commissioner, 61 T.C. 564, 568 (1974), affd. 528
F.2d 176 (10th Cir. 1975); see also Cohan v. Commissioner, 39 F.2d
540 (2d Cir. 1930).
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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