- 14 - Petitioner's strength revealed itself during the economic slowdown. Ginger had aligned petitioner with the large developers, the most likely candidates to build during the downturn. By this time, however, bid prices were critical in obtaining work. Ginger studied the jobsites of his competitors and talked to their customers and suppliers in an attempt to determine whether a competitor could bid a lower price than petitioner. These were additional duties that Ginger took on as a result of the economic slowdown. In addition, Ginger reviewed an industrywide credit report that indicated whether petitioner's competitors were experiencing credit problems. Many other construction-related companies lost business during the fall of 1990 and some went out of business entirely. John Connors (Connors), vice president of a construction materials supply company, held an emergency meeting with the executives of his company in September 1990 to address the economic downturn. Connors' stores suffered a 40-percent to 60- percent drop in sales. Connors' company reduced its staff from 145 to 80 and reduced salaries across the board by 10 percent. OPINION Section 162(a)(1) allows a corporation to deduct "a reasonable allowance for salaries or other compensation for personal services actually rendered" as a business expense. To come within the ambit of section 162(a)(1), the compensation must be both reasonable in amount and in fact paid purely forPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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