- 85 - 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 ofPage: Previous 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 Next
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