- 15 -
For the aforesaid reasons, the evidence does not persuade us
that petitioner paid the accrued bonus by means of a promissory
note before the close of the taxable year in issue. Petitioner
has not satisfied its burden of proof. We therefore sustain
respondent’s disallowance of the deduction.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011