Summit Sheet Metal Co. - Page 9

                                        - 9 -                                         

          Searing each received equal amounts of the net profits from                 
          Summit Supply Co.                                                           
               Chasin, Hanson, and Searing owned North County Builders with           
          Sherman and Harris (neither of whom is otherwise described in the           
          record).  North County Builders was developing an apartment house           
          project in the year in issue.                                               
          C.   Bonuses Paid to Chasin, Hanson, and Searing                            
               1.   Petitioner's Bonus Payment Procedures                             
               Petitioner authorized bonuses each year for its officers for           
          their services.  Petitioner's board of directors (Chasin, Hanson            
          and Searing) authorized the bonuses to be paid when petitioner's            
          cash position reasonably permitted, but not later than September            
          15 of each taxable year from 1966 to 1986 except 1971 and 1972.             
          In taxable years 1971 and 1972, petitioner's board of directors             
          authorized an approximate amount for a combined salary and bonus            
          for each officer.                                                           
               Chasin, Hanson, and Searing met each year to consider                  
          factors such as petitioner's success, development, profits,                 
          needs, and tax considerations and their own tax considerations in           
          deciding the amount of the bonuses.  Chasin, Hanson, and Searing            
          agreed unanimously on the amounts of their bonuses each year,               
          including the year in issue.  Each year, Chasin, Hanson, and                








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011