- 2 - Halvor N. Adams III and Thomas J Kerrigan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Pulsar Components International, Inc., petitioned the Court to redetermine respondent's determination of a $382,771 deficiency in its income tax for its taxable year ended July 31, 1985. Respondent determined that $822,000 of the $2,922,000 claimed by petitioner as officers' compensation was unreasonable. In an amendment to her answer, respondent asserted that $2,324,170 of the claimed compensation was unreasonable, increasing the claimed deficiency to $1,089,369. Respondent also asserted in the amendment that petitioner was liable for an addition to tax under section 6661. We must decide the amount of compensation paid by petitioner that is reasonable and thus deductible as a business expense under section 162. We hold all of it is.1 Unless otherwise stated, section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. We separately refer to Thomas F. Laviano and Peter T. Woll as Mr. Laviano and Mr. Woll, respectively. We collectively refer to them as the Officers. FINDINGS OF FACT 1 Accordingly, we also hold that petitioner is not liable for the addition to tax asserted by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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