Sunbelt Clothing Company, Inc., f.k.a. Unprinted T-Shirt Warehouse, Inc. - Page 12

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               During fiscal years 1990 through 1992, Messrs. Bennett and             
          Sokol were paid the following salaries:                                     

          FYE            Mr. Bennett          Mr. Sokol                               
          7/29/90           $2,030,000          $670,000                              
          7/28/91            2,030,000           670,000                              
          8/02/92            2,050,192           173,077                              

          Petitioner deducted these amounts.                                          
               In the notice of deficiency, respondent disallowed                     
          petitioner's deductions for salaries paid to Messrs. Bennett and            
          Sokol that were in excess of the following amounts:                         

          FYE            Mr. Bennett         Mr. Sokol                                
          7/29/90           $485,027           $230,202                               
          7/28/91            541,273            252,634                               
          8/02/92            585,391             1N/A                                 

               1Compensation paid to Mr. Sokol for the 1992 fiscal year is            
          not in dispute.                                                             

                                       OPINION                                        

               The sole issue for decision is whether the amounts                     
          petitioner paid to Messrs. Bennett and Sokol from fiscal years              
          1989 through 1992 constituted reasonable compensation for                   
          services rendered within the meaning of section 162(a)(1).3                 

               3Sec. 162(a)(1) allows as a deduction a reasonable allowance           
          for compensation for personal services actually rendered.                   
          Respondent concedes that the amount of any compensation found to            
                                                             (continued...)           




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