William J. and Sandra D. Heitz - Page 10

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          December 31, 1992 and 1993, Exacto held cash, cash equivalents,             
          and marketable securities in the amounts of $2,792,123 and                  
          $3,129,900, respectively.  Respondent determined that Mr. and               
          Mrs. Heitz had constructively received interest income in the               
          amounts of $87,056 and $106,903 for 1992 and 1993, respectively.            
                                       OPINION                                        
          Issue 1.  Reasonable Compensation                                           
               Section 162(a)(1) provides for a deduction for ordinary and            
          necessary business expenses including a “reasonable allowance for           
          salaries or other compensation for personal services actually               
          rendered”.  A two-prong test determines deductibility:                      
          (1) Whether the amount of compensation is reasonable in relation            
          to services performed, and (2) whether the payment is in fact               
          purely for services rendered.  Summit Publg. Co. v. Commissioner,           
          T.C. Memo. 1990-288; sec. 1.162-7(a), Income Tax Regs.  The                 
          inquiry into reasonableness is a broad one and generally subsumes           
          the inquiry into compensatory intent.  Summit Publg. Co. v.                 
          Commissioner, supra.  Petitioner must show the reasonableness of            
          the compensation.  Rule 142(a).                                             
               The reasonableness of compensation is a question of fact to            
          be answered by considering and weighing all facts and                       
          circumstances of the particular case.  Estate of Wallace v.                 








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