- 22 - ceived and reviewed petitioner's financial statements and had regular discussions with Mr. Ruf concerning petitioner. At no time during those years did Mr. Neiman disapprove the compensa- tion petitioner paid to Mr. Ruf. Although the original notes initially restricted the amount of cash that Mr. Ruf was allowed to withdraw from petitioner due to its poor cash position, Mr. Neiman expected that Mr. Ruf would be justly compensated as soon as the cash was available to do so. Notice of Deficiency In the notice of deficiency (notice), respondent allowed the entire amount of $132,629 that petitioner deducted as compen- sation paid to Mr. Ruf in its Federal income tax return for its taxable year ended February 29, 1988, and disallowed $1,322,053, $2,600,000, and $750,000 of the amounts that petitioner deducted as compensation paid to Mr. Ruf in its Federal income tax returns for its taxable years ended February 28, 1989, February 28, 1990, and February 28, 1991, respectively. Respondent thus determined that petitioner was entitled to deduct as compensation paid to Mr. Ruf $132,629 for its taxable year ended February 29, 1988, $132,693 for its taxable year ended February 28, 1989, and $0 for its taxable years ended February 28, 1990, and February 28, 1991.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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