- 12 - 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...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011