Summit Sheet Metal Co. - Page 22

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                    f.   Taxpayer's Salary Policy to All Employees                    
               Courts have considered the taxpayer's salary policy for its            
          other employees in deciding whether compensation is reasonable.             
          Home Interiors & Gifts, Inc. v. Commissioner, supra at 1159.                
          There is no evidence that petitioner has a formal policy for                
          setting salaries for its officers or other employees.  Because              
          the record is not clear on this point, we do not apply this                 
          factor.                                                                     
                    g.   Taxpayer's Financial Condition                               
               The past and present financial condition of the company is             
          relevant to deciding whether compensation is reasonable.  Id. at            
          1157-1158.                                                                  
               Petitioner grew from total equity (capital stock and paid-in           
          surplus) of $65,579 to $2,020,646 for the year in issue.                    
          Petitioner always made a profit.  For the year in issue,                    
          petitioner's gross profit was 41 percent of gross income, return            
          on sales was 10.3 percent, return on assets was 22.5 percent, and           
          return on equity was 33 percent.  Petitioner's officers'                    
          compensation decreased 16.3 percent as a percentage of net sales            
          from the year before the year in issue to the year in issue while           
          its sales and gross profit increased nearly 30 percent.                     
               Petitioner points out that a survey by the Sheet Metal and             
          Air-Conditioning Contractors' National Association (SMACNA) dated           







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