Tricon Metals & Services, Inc. - Page 2

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          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.                                                      







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