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167, 173 (6th Cir. 1982), revg. 72 T.C. 793 (1979); Mayson
Manufacturing Co. v. Commissioner, 178 F.2d 115, 119 (6th Cir.
1949), revg. a Memorandum Opinion of this Court.
The Court of Appeals for the Sixth Circuit, the court to
which an appeal in this case lies, has adopted a set of basic
factors to be considered by the Court in deciding the
reasonableness of compensation: (1) The employee's
qualifications; (2) the nature, extent, and scope of the
employee's work; (3) the size and complexities of the employer's
business; (4) a comparison of salaries paid with the employer's
gross and net income; (5) the prevailing general economic
conditions; (6) a comparison of salaries paid with distributions
of retained earnings; (7) the prevailing rates of compensation
for comparable positions in comparable concerns; (8) the salary
policy of the employer as to all employees; and (9) in the case
of small corporations with a limited number of officers, the
amount of compensation paid to the particular employee in
previous years. Kennedy v. Commissioner, supra at 173-174;
Mayson Manufacturing Co. v. Commissioner, supra. The facts must
be considered as a whole with no single factor decisive. Mayson
Manufacturing Co. v. Commissioner, supra.
Petitioners urge the Court to find that respondent erred in
determining that any amounts of employee wages were paid to
Michael and Jody. In other words, they do not argue that a
finding of lesser amounts of employee wages would be more
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