- 26 - petitioner's officers' compensation because of the officers' successful leadership of petitioner. This factor tends to show that the compensation at issue for services to petitioner was reasonable. 3. Conclusion We conclude that the compensation of petitioner's officers in the year in issue was reasonable because of their qualifications and the scope of their duties, petitioner's size, growth, and financial success, the officers' compensation in relation to petitioner's sales, and the fact that, according to the SMACNA survey, the taxpayer performed well compared to other reasonably comparable firms. C. Whether Petitioner May Change the Year It Deducts Bonuses Without Respondent's Consent 1. Contentions of the Parties Petitioner seeks to change the year it deducts its officers' bonuses from the year it authorized them, as petitioner reported on its return, to the following taxable year, in which the officers received and reported the bonuses. Respondent contends that petitioner needed but did not have respondent's permission to change the year it deducted its officers' bonuses.4 Sec. 446(e). 4Petitioner contends that respondent’s contention that (continued...)Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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