Pulsar Components International, Inc. - Page 26

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          of dividends and the amounts thereof as reasonable business                 
          decisions.7  Petitioner paid $65,000 in dividends in the year at            
          issue.  Its shareholder’s equity grew from $63,903 on July 31,              
          1983, to $960,582 on July 31, 1985.  Its retained earnings grew             
          from $62,902 on July 31, 1983, to $959,582 on July 31, 1985.                
          See Comtec Sys., Inc. v. Commissioner, T.C. Memo. 1995-4.  In               
          addition to the fact that the increase in petitioner's retained             
          earnings most likely increased the value of its stock, we believe           
          that a hypothetical investor would have considered $959,582 in              
          retained earnings to have been a worthy performance for the                 
          3-year period.  Moreover, the Officers received dividends from              
          petitioner's earnings.  The dividends per share increased from              
          $95 per share on July 31, 1984, to $617.50 per share on July 31,            
          1985.  On this record, it is clear that an investment in                    
          petitioner's stock was very attractive and that the Officers                
          received an adequate share of petitioner's profits through                  
          dividends.  This factor favors petitioner.                                  
             h.  Prevailing Rates of Compensation for Comparable                      
             Positions in Comparable Companies                                        
             Both petitioner and respondent rely on expert testimony with             
          respect to this factor.  Expert testimony is appropriate to help            


          7 Bearing in mind that respondent has not determined that                   
          petitioner is liable for the accumulated earnings tax of sec.               
          531, it is possible that she would agree that the large increase            
          in petitioner's retained earnings was necessary for the                     
          reasonable needs of petitioner's business.                                  




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