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compensation for Choate in 1992, as petitioner contends;
$265,550, as respondent contends; or some other amount. We hold
that petitioner may deduct $1,010,000.
Section references are to the Internal Revenue Code as in
effect for the relevant periods. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner's principal place of business was in Marietta,
Georgia, when it filed the petition in this case.
Petitioner is a construction company that specializes in
building medical facilities (e.g., operating rooms), biomedical
and "clean rooms" for laboratories, highly sophisticated
industrial and robotics facilities, and plants that manufacture
glass. Businesses use "clean rooms" to manufacture computer
chips and pharmaceuticals and for activities that require a
sterile environment of up to 100 times cleaner than a hospital
operating room.
Petitioner's 1992 tax year started on July 1, 1991, and
ended on June 30, 1992. Petitioner became an S corporation on
July 1, 1993.
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