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salaries or other compensation for personal services actually
rendered". A two-prong test determines deductibility: (1)
Whether the amount of compensation is reasonable in relation to
services performed, and (2) whether the payment is in fact purely
for services rendered. Elliotts, Inc. v. Commissioner, 716 F.2d
1241, 1243 (9th Cir. 1983), revg. T.C. Memo. 1980-282; Nor-Cal
Adjusters v. Commissioner, 503 F.2d 359, 362 (9th Cir. 1974),
affg. T.C. Memo. 1971-200; sec. 1.162-7(a), Income Tax Regs. The
decision as to the deductibility of compensation generally
focuses on the reasonableness of the compensation. Elliotts,
Inc. v. Commissioner, supra at 1245. Petitioner bears the burden
of proving the reasonableness of the compensation. Rule 142(a);
Botany Worsted Mills v. United States, 278 U.S. 282 (1929).
The reasonableness of compensation is a question of fact to
be answered by considering and weighing all facts and
circumstances of the particular case. Pacific Grains, Inc. v.
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo.
1967-7; Estate of Wallace v. Commissioner, 95 T.C. 525, 553
(1990), affd. 965 F.2d 1038 (11th Cir. 1992). The cases provide
a lengthy list of factors that bear on the determination of
reasonableness. Mayson Manufacturing Co. v. Commissioner, 178
F.2d 115, 119 (6th Cir. 1949); Foos v. Commissioner, T.C. Memo.
1981-61. No single factor is decisive. Pacific Grains, Inc. v.
Commissioner, supra at 606. In Elliotts, Inc. v. Commissioner,
supra, the Court of Appeals for the Ninth Circuit, to which this
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