- 48 - Year Ended Amount of Compensation Feb. 29, 1988 $600,000 Feb. 28, 1989 400,000 We further find that the remaining $1,600,000 of the $2,600,000 that petitioner paid Mr. Ruf during its fiscal year ended February 28, 1990, was for services he provided during that year and that only $800,000 of that amount was a reasonable amount of compensation for those services.26 Accordingly, we find that a total of $1,800,000 constitutes reasonable compensation within the meaning of section 162(a)(1) for which petitioner is entitled 26 To summarize, based on our review of the entire record in this case, we find that the following are reasonable amounts of compensation to Mr. Ruf for the indicated years: Year Ended Reasonable Compensation Feb. 28, 1987 $1,128,936 Feb. 29, 1988 832,629 Feb. 28, 1989 632,693 Feb. 28, 1990 800,000 Feb. 28, 1991 750,000 We note that in the notice, at trial, and/or on brief, respondent allowed the total amounts of compensation that petitioner deduct- ed in its returns for its taxable years ended Feb. 29, 1988, Feb. 28, 1989, and Feb. 28, 1991. Respondent also conceded on brief the $73,117 of interest petitioner deducted in its Federal income tax return for its taxable year ended Feb. 28, 1989, that was related to the $315,603 of compensation awarded pursuant to the management agreement. Consequently, our findings herein affect petitioner's Federal income tax liability only for its taxable year ended Feb. 28, 1990, and not for its taxable years ended Feb. 29, 1988, Feb. 28, 1989, and Feb. 28, 1991.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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