Pulsar Components International, Inc. - Page 19

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          qualifications; (b) the nature, extent, and scope of the                    
          employee's work; (c) the size and complexities of the employer's            
          business; (d) a comparison of salaries paid with the employer's             
          gross and net income; (e) the prevailing general economic                   
          conditions; (f) a comparison of salaries with distributions to              
          Officers and retained earnings; (g) the prevailing rates of                 
          compensation for comparable positions in comparable concerns;               
          (h) the salary policy of the employer as to all employees;                  
          (i) the amount of compensation paid to the particular employee in           
          previous years; (j) the employer's financial condition;                     
          (k) whether the employer and employee dealt at arm's length;                
          (l) whether the employee guaranteed the employer's debt;                    
          (m) whether the employer offered a pension plan or profit-sharing           
          plan to its employees; and (n) whether the employee was                     
          reimbursed by the employer for business expenses that the                   
          employee paid personally.  See Rutter v. Commissioner, 853 F.2d             
          1267, 1274 (5th Cir. 1988), affg. T.C. Memo. 1986-407; Elliotts,            
          Inc. v. Commissioner, supra at 1245-1248; Kennedy v.                        
          Commissioner, 671 F.2d 167, 174 (6th Cir. 1982), revg. and                  
          remanding 72 T.C. 793 (1979); Charles Schneider & Co. v.                    
          Commissioner, supra at 151-152; Mayson Manufacturing Co. v.                 
          Commissioner, supra at 119; Estate of Wallace v. Commissioner,              
          supra at 553; Home Interiors & Gifts, Inc. v. Commissioner,                 
          73 T.C. 1142, 1155-1156 (1980); see also Mad Auto Wrecking, Inc.            





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