- 15 - Respondent determined a deficiency in petitioner's income tax of $307,671 for 1987. Respondent’s determination is presumed to be correct, and petitioner bears the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). B. Whether Petitioner Paid Unreasonable Compensation to its Officers in the Year in Issue Petitioner contends that it deducted an unreasonable amount for officers’ compensation for the year in issue. Petitioner contends that a total of no more than $421,938 is reasonable compensation for its three officers. Respondent contends that the compensation petitioner paid and deducted ($618,295) was reasonable. 1. Whether All of the Compensation Was Paid for Services Provided to Petitioner A corporation may deduct "a reasonable allowance for salaries or other compensation for personal services actually rendered". Sec. 162(a)(1). Reasonable compensation must be purely for services provided to the company which provides the compensation. Elliotts, Inc. v. Commissioner, 716 F.2d 1241, 1243 (9th Cir. 1983), revg. and remanding T.C. Memo. 1980-282; sec. 1.162-7(a), Income Tax Regs. Petitioner contends that Searing and Hanson spent a substantial amount of time in the years in issue working forPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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