- 2 -2 FYE Aug. 31 Deficiency 1990 $173,346 1991 226,072 1992 326,591 The issue for decision is whether the compensation paid to petitioner's majority shareholder in its fiscal years ending 1990, 1991, and 1992 is deductible by petitioner as reasonable compensation under section 162(a)(1). We hold that it is to the extent stated herein. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. FINDINGS OF FACT We incorporate by reference the stipulation of facts and attached exhibits. Tricon Metals & Services, Inc. (petitioner), is an Alabama corporation whose principal place of business was Jefferson County, Alabama, when the petition was filed. Petitioner operates on a fiscal year ending August 31. 1. Petitioner Petitioner buys, warehouses, and sells high-strength steel products. Petitioner's founders, James L. Bell (Bell), Walter H. Ferguson (Ferguson), and W. Warren Wood (Wood), worked as salesmen for other companies in the steel business prior to organizing petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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