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Feb. 28, 1989 933,000
Feb. 28, 1990 1,000,000
Feb. 28, 1991 750,000
Respondent counters that Mr. Ruf earned the $933,333 in
compensation petitioner paid him pursuant to the 1987 deferred
compensation arrangement during the years for which it was to
accrue under that arrangement,19 that Mr. Ruf was not undercom-
pensated for any years prior to petitioner's fiscal year ended
February 28, 1990, and that petitioner is entitled to deduct only
$500,000 as reasonable compensation to Mr. Ruf for its taxable
year ended February 28, 1990. Thus, according to respondent,
petitioner awarded the following amounts of compensation to Mr.
Ruf for the indicated years, and only those amounts are reason-
able:
Year Ended Compensation
Feb. 28, 1987 $395,603
Feb. 29, 1988 565,629
Feb. 28, 1989 632,693
Feb. 28, 1990 500,000
Feb. 28, 1991 750,000
19 Respondent contends that, of the $933,000 that petitioner
paid Mr. Ruf pursuant to the 1987 deferred compensation arrange-
ment, $433,000 was to accrue for petitioner's fiscal year ended
Feb. 29, 1988, and $500,000 was to accrue for its fiscal year
ended Feb. 28, 1989. It appears to us that the respective
amounts that respondent contends were to accrue for those years
pursuant to the 1987 deferred compensation arrangement should be
reversed (i.e., it appears that $500,000 was to accrue for peti-
tioner's fiscal year ended Feb. 29, 1988, and $433,000 was to
accrue for its fiscal year ended Feb. 28, 1989).
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