- 15 - comparable positions in comparable companies; (11) compensation paid in prior years; and (12) whether the employee guaranteed the employer's debt. Rutter v. Commissioner, supra; Owensby & Kritikos, Inc. v. Commissioner, supra; Mayson Manufacturing Co. v. Commissioner, 178 F.2d 115, 119 (6th Cir. 1949), revg. and remanding a Memorandum Opinion of this Court dated Nov. 16, 1948; R.J. Nicoll Co. v. Commissioner, 59 T.C. 37, 51 (1972). No single factor controls. Mayson Manufacturing Co. v. Commissioner, supra. 2. Post-June 30, 1992, Facts The last day of the tax year at issue was June 30, 1992. Respondent objected to the admission of evidence relating to some post-June 30, 1992, events as irrelevant.1 Petitioner relies on events occurring after June 30, 1992, to show Choate's value to petitioner in the year ending June 30, 1992, and to rebut 1 Respondent does not argue on brief that we should not consider events occurring after June 30, 1992. On brief, respondent points out that Choate lent money to petitioner from June 2, 1992, to June 29, 1993, when he was receiving large bonuses from petitioner. Respondent's expert testified that he would consider petitioner's 1994, 1995, and 1996 financial success in estimating Choate's reasonable compensation for 1992 because the performance of an officer in a construction company affects the firm in later years.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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