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provided some services to other related entities, we are unable
to find that these services were performed on behalf of anyone
other than petitioner. We hold that petitioner paid the Officers
the subject compensation for services that they rendered to it.
3. Conclusion
Based on the above, we conclude that petitioner may deduct
the $1,461,000 that it paid to Mr. Laviano, and it may deduct the
$1,461,000 that it paid to Mr. Woll. In so concluding, we have
considered all arguments made by respondent for a contrary
holding and, to the extent not discussed above, we find them to
be without merit.
To reflect the foregoing,
Decision will be entered
for petitioner.
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