Medieval Attractions N.V - Page 138

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          are not deductible.  Latham Park Manor, Inc. v. Commissioner, 69            
          T.C. 199, 218 (1977), affd. without published opinion 618 F.2d              
          100 (4th Cir. 1980).                                                        
               The cases contain a lengthy list of factors that are                   
          relevant in the determination of reasonableness of compensation,            
          including:  The employee’s qualifications; the nature, extent,              
          and scope of the employee’s work; the size and complexities of              
          the business; a comparison of salaries paid with gross income and           
          net income; the prevailing general economic conditions; a                   
          comparison of salaries with distributions to stockholders; the              
          prevailing rates of compensation for comparable positions in                
          comparable concerns; the salary policy of the taxpayer as to all            
          employees; and the amount of compensation paid to the particular            
          employee in previous years.  Mayson Manufacturing Co. v.                    
          Commissioner, 178 F.2d 115, 119 (6th Cir. 1949), revg. a                    
          Memorandum Opinion of this Court dated Nov. 16, 1948.                       
               Petitioners applied to the facts in the instant cases the              
          factors listed in Mayson Manufacturing Co. and conclude in their            
          brief that “it is clear that the management and consulting fees             
          at issue were ordinary, necessary, reasonable and consistent with           
          an arm’s-length charge.”  The facts on which petitioners base               
          their conclusion include Eurotor’s oversight of the Medieval                
          Times operations, RC’s catering and ranch operations, and Segui’s           
          and Santandreu’s positions as members of various boards of                  






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