Medieval Attractions N.V - Page 142

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          the renegotiation resulted in additional fees of approximately              
          $20,000 per year.                                                           
               The Eurotor MANV/MDT management contract also had a fee of             
          2 percent of gross production.  Notwithstanding that the contract           
          was probably not ratified until 1987, the castle opened in 1986             
          and the operation’s profitability was untested at the time the              
          fee was determined.                                                         
               In Good Chevrolet v. Commissioner, T.C. Memo. 1977-291, this           
          Court addressed the reasonableness of compensation paid to two              
          employees of an automobile dealership.  The two employees held              
          100 percent of the corporation’s stock.  The issue was whether              
          bonuses that constituted predetermined percentages of profits               
          were reasonable.  The facts that tended to support a finding of             
          excess compensation included:  The two shareholders controlled              
          the corporation's finances; the amount of net income paid out as            
          bonuses during the years in issue approximated 60 percent per               
          year; and the success of the business was due in part to                    
          fortuitous economic conditions and not to altered or augmented              
          endeavors by them.  The facts that tended to support the                    
          reasonableness of the compensation included:  The business was              
          extraordinarily successful, due in part to programs instituted by           
          the shareholders; the shareholders were astute, aggressive                  
          businessmen; and, although a percentage of the profits was                  
          determined before one shareholder had a controlling interest in             






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