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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
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