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Inc. v. Commissioner, 819 F.2d at 1325 n.33; R.J. Nicoll Co. v.
Commissioner, 59 T.C. 37, 51 (1972); see also Acme Constr. Co. v.
Commissioner, T.C. Memo. 1995-6; BOCA Constr., Inc. v.
Commissioner, T.C. Memo. 1995-5. Here, both Messrs. Bennett and
Sokol personally guaranteed the repayment of petitioner's multi-
million dollar revolving line-of-credit.
3. Size and Complexities of the Employer's Business
Courts have considered the size and complexity of a
taxpayer’s business in deciding whether compensation is
reasonable. Pepsi-Cola Bottling Co. v. Commissioner, 528 F.2d
176, 179 (10th Cir. 1975), affg. 61 T.C. 564 (1974).
Petitioner's gross sales--an indicator of its size--were
$54,455,167, $69,748,749, and $70,059,961, respectively, for
fiscal years 1990, 1991, and 1992. By 1990, petitioner's
operations involved rental space in six separate warehouses and
eventually required the construction of a 150,000-square foot
distributing center with a computerized inventory tracking system
to handle the sales volume. In addition, petitioner employed
approximately 200 people during the years in issue.
4. Comparison of Salaries Paid to Net and Gross Income
Courts have compared sales, net income, and capital value to
amounts of compensation in deciding whether compensation is
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