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creativity. This factor favors petitioner. See Elliotts, Inc.
v. Commissioner, supra at 1245-1246; Kennedy v. Commissioner,
supra at 176; Home Interiors & Gifts, Inc. v. Commissioner, supra
at 1158; Dave Fischbein Manufacturing Co. v. Commissioner, supra
at 352-353.
d. Size and Complexities of the Employer's Business
Courts have considered the size and complexity of a
taxpayer’s business in deciding whether compensation is
reasonable. Elliotts, Inc. v. Commissioner, supra at 1246;
Pepsi-Cola Bottling Co. v. Commissioner, 528 F.2d 176, 179
(10th Cir. 1975), affg. 61 T.C. 564 (1974); Mayson Manufacturing
Co. v. Commissioner, 178 F.2d at 119.
Petitioner is a highly specialized semiconductor trading
company, and its split-second trading operations demand
expertise. Petitioner's business is highly competitive, with
thousands of competitors trying to locate and sell the same parts
as petitioner. Petitioner's unique trading method introduced by
the Officers enabled it to survive and become extremely
profitable in a highly competitive industry. Petitioner's gross
receipts during the year in issue totaled more than $10 million.
This factor favors petitioner. See Elliotts, Inc. v.
Commissioner, supra at 1246.
e. Comparison of Salaries Paid to Net and Gross Income
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