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whole with no single factor decisive. Mayson Manufacturing Co.
v. Commissioner, supra.
In analyzing these factors, the Court must carefully
scrutinize the facts of a case in which the paying corporation is
controlled by an employee to whom the compensation is paid. For
example, section 1.162-7(b)(1), Income Tax Regs., cautions that
in the case of a corporation having few shareholders, "An
ostensible salary paid by a corporation may be a distribution of
a dividend on stock." See Estate of Wallace v. Commissioner,
supra at 555. In such a situation, we must be convinced that the
purported compensation was paid for services rendered by the
employee as opposed to a distribution of earnings to him that the
employer could not deduct. RTS Inv. Corp. v. Commissioner, 877
F.2d 647, 650 (8th Cir. 1989), affg. per curiam T.C. Memo. 1987-
98; Seven Canal Place Corp. v. Commissioner, 332 F.2d 899 (2d
Cir. 1964), remanding T.C. Memo. 1962-307.
1. Rogers' Qualifications
An employee's superior qualifications for his or her
position with the business may justify high compensation. See,
e.g., Home Interiors & Gifts, Inc. v. Commissioner, supra at
1158; Dave Fischbein Manufacturing Co. v. Commissioner, 59 T.C.
338, 352-353 (1972).
Although Rogers had no formal training in business
management, he has more than 25 years of practical business
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