- 12 - Petitioner deducted the following Officers' compensation on its Federal corporate income tax returns for those years as follows: Taxable Year Ended Deduction Claimed July 31 Mr. Laviano Mr. Woll Total 1983 $11,000 $15,000 $26,000 1984 729,000 720,000 1,449,000 1985 1,461,000 1,461,000 2,922,000 Total 2,201,000 2,196,000 4,397,000 A comparison of the Officers' compensation and their stock ownership interests is as follows: Taxable Year Ended July 31 Mr. Laviano (55%) Mr. Woll (40%) 1983 42.3% 57.7% 1984 50.3 49.7 1985 50.0 50.0 d. Board Resolution Concerning Undercompensation Petitioner's board met on August 6, 1984, and reported that each of the Officers was actually paid less than the amounts that were fixed in their employment agreements. Specifically, the board found, the Officers were entitled to receive $650,000 per year, but were actually paid the following amounts: 1983 1984 Thomas Laviano $11,000 $729,000 Peter Woll 15,000 720,000 The board decided that petitioner owed Mr. Laviano $560,000 and that petitioner owed Mr. Woll $565,000. The board unanimouslyPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011