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FYE
June 30 Deficiency
1990 $227,677
1991 52,981
1992 72,081
The issue for decision is whether the compensation paid to
petitioner's shareholder in its fiscal years ending 1990 and 1992
is deductible by petitioner as reasonable compensation under
section 162(a)(1). We hold that it is.
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
FINDINGS OF FACT
We incorporate by reference the stipulation of facts and
attached exhibits. John L. Ginger Masonry, Inc. (petitioner), is
a California corporation whose principal place of business was in
Riverside, California, when the petition was filed. Petitioner
operates on a fiscal year ending June 30. The deficiency
determined by respondent for the fiscal year ended June 30, 1991,
stems solely from adjustments tied to the fiscal years ended June
30, 1990, and June 30, 1992.
A. Petitioner
Petitioner is a masonry contractor that specializes in
brick, stone, and block masonry. Petitioner's founder, John L.
Ginger (Ginger), has spent his entire career in the construction
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