PMT, INC. - Page 13

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          its salespeople was between 1.5 and 4 percent of sales.  In 1990,           
          the top salesperson for petitioner was Mr. Saldias, who earned              
          $337,182.59 in commissions for the calendar year 1990.                      
               On July 31, 1990, Mr. Penalba loaned $689,454.42 to                    
          petitioner, and Mrs. Penalba loaned $172,363.61 to petitioner.              
          Petitioner's income tax return for its fiscal year 1990 shows               
          that at the beginning of the year its loans from stockholders               
          were $822,941 and at the end of the year were $1,233,246.  Mrs.             
          Penalba loaned substantial sums of money to petitioner over the             
          years in order to establish more working capital to enable                  
          petitioner to receive further credit from suppliers and vendors.            
               On its income tax return for its fiscal year 1990,                     
          petitioner claimed a deduction for compensation paid to Mr.                 
          Penalba of $1,342,400 and for compensation paid to Mrs. Penalba             
          of $407,600.  Respondent in her notice of deficiency determined             
          that reasonable compensation for petitioner's officers during its           
          fiscal year 1990 was $875,000 and disallowed as a deduction                 
          $875,000 of the $1,750,000 claimed by petitioner on its income              
          tax return for officers' compensation for that year.  Respondent            
          determined that reasonable compensation for Mr. Penalba for                 
          petitioner's fiscal year 1990 was $671,200 and that reasonable              
          compensation for Mrs. Penalba was $203,800.  Respondent also                
          determined that petitioner's closing inventory for its fiscal               
          year 1990 was undervalued by $379,819.  At the trial, counsel for           
          respondent explained that part of the undervaluing of inventory             




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