H & A International Jewelry, Ltd. - Page 12

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          proves respondent's determination erroneous, the Court must then            
          decide the amount of compensation that was reasonable.  Pepsi-              
          Cola Bottling Co. v. Commissioner, 61 T.C. 564, 568 (1974), affd.           
          528 F.2d 176 (10th Cir. 1975).                                              
               The reasonableness of compensation is a question of fact to            
          be determined from the record in each case.  Estate of Wallace v.           
          Commissioner, 95 T.C. 525, 553 (1990), affd. 965 F.2d 1038 (11th            
          Cir. 1992).  In Estate of Wallace v. Commissioner, we used the              
          following nine factors to determine reasonableness:  (1) the                
          employee's qualifications; (2) the nature, extent, and scope of             
          the employee's work; (3) the size and complexities of the                   
          business; (4) a comparison of salaries paid with the gross income           
          and the net income; (5) the prevailing general economic                     
          conditions; (6) comparison of salaries with distributions to                
          stockholders; (7) the prevailing rates of compensation for                  
          comparable positions in comparable concerns; (8) the salary                 
          policy of the corporation as to all employees; and (9) in the               
          case of small corporations with a limited number of officers, the           
          amount of compensation paid to the particular employee in                   
          previous years.  Estate of Wallace v. Commissioner, supra at 553;           
          see also Mayson Manufacturing Co. v. Commissioner, 178 F.2d 115,            
          119 (6th Cir. 1949).  All the facts must be considered; no one              
          factor is determinative.  Rutter v. Commissioner, 853 F.2d 1267,            
          1274 (5th Cir. 1988), affg. T.C. Memo. 1986-407; Pacific Grains,            






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