Pulsar Components International, Inc. - Page 24

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          and indicate the extent (if any) of the employees effect on the             
          company.  Mayson Manufacturing Co. v. Commissioner, supra at                
          119-120.  Adverse economic conditions, for example, tend to show            
          that an employee's skill was important to a company that grew               
          during the bad years.                                                       
             Because petitioner's industry seeks to take advantage of                 
          supply imbalances present in the computer chip/semiconductor                
          market, it is characterized by periods of rapid growth and                  
          profitability followed by periods of sharp decline.  Petitioner             
          faced declining sales during the subject year as market                     
          imbalances in supply began to correct themselves, and petitioner            
          was forced to compete with an increasing number of competitors.             
          Although petitioner's gross receipts declined significantly,                
          petitioner experienced an increase in its taxable income,                   
          retained earnings, and shareholder’s equity.  The adverse                   
          economic conditions tend to show that the Officers' skill and               
          diligence were important to petitioner's success.  This factor              
          favors petitioner.                                                          
             g.  Comparison of Salaries With Distributions to                         
             Officers and Retained Earnings                                           
             The failure to pay more than minimal dividends may suggest               
          that reported compensation actually is (in whole or in part) a              
          dividend.  Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d               
          1315, 1322-1323 (5th Cir. 1987), affg. T.C. Memo. 1985-267;                 
          Charles Schneider & Co. v. Commissioner, 500 F.2d at 151.                   




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