Pulsar Components International, Inc. - Page 2

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               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.                             




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