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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.
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