Summit Sheet Metal Co. - Page 26

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          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...)           





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