- 12 - appropriate and, due primarily to their failure to introduce any corporate books and records, have not presented any credible evidence upon which lesser amounts of employee wages may be determined. Respondent's determinations were based on the only records available, the corporation's bank statements, from which respondent determined that regular payments were made to and on behalf of Michael and Jody. The record firmly establishes the fact that Michael was the driving force behind the corporation's business during the taxable years in issue. At trial, Michael acknowledged his reputation as being highly regarded in the construction industry and his role as the corporation's "rainmaker". We are not convinced that Michael's participation in the corporation's activities was drastically reduced after 1992. We believe that he remained in complete control of the corporation even after Jody began working for it. Jody's role in the corporation, while not as influential as his father's, certainly would have demanded the modest salary that respondent determined he received. After carefully considering the factors listed above, we find that respondent's determinations of the amounts of Michael's and Jody's employee wages for the taxable years in issue constitute reasonable compensation for the services which they provided to the corporation as employees during such years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011