- 13 - (Reynolds), a surety bond agent, worked with Choate for petitioner, and with Barrett, Freese, and Dudley for their own companies. Reynolds used the following criteria to evaluate the companies owned by Barrett, Freese, Dudley, and Choate when they sought surety bonds: (1) The character and integrity of the key individual, (2) the capacity and experience of the company to perform projects they want to undertake, and (3) the amount of cash in or the financial ability of the company to perform the contracts. OPINION A. Contentions of the Parties Petitioner deducted the $1,010,000 which it paid to Choate in 1992. Respondent determined and contends that it was unreasonable to pay Choate more than $265,550, and that part of the $1,010,000 was not for services that Choate rendered to petitioner in 1992. Respondent's determination is presumed to be correct. Rule 142(a). B. Background A taxpayer may deduct a reasonable allowance for salaries or other compensation for services actually rendered. Sec.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011