- 11 - 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 morePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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