- 2 - All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. After concessions,1 the issues for decision are: (1) The amount petitioner is entitled to deduct under section 162 as reasonable compensation to its president Lon Martin for its year ended June 30, 1990. We find it is entitled to deduct $406,000. (2) Whether petitioner is liable for an accuracy-related penalty under section 6662(a) and (b)(2) for the year ended June 30, 1990, with respect to its claimed deduction for the compensation to Lon Martin. We hold that it is not liable for the penalty. FINDINGS OF FACT Some of the facts and certain documents have been stipulated for trial pursuant to Rule 91 and are found accordingly. We incorporate the parties' stipulations in this opinion by reference. Petitioner is an Oregon corporation. When its petition herein was filed, petitioner maintained its principal office in Portland, Oregon. 1Among other things, respondent concedes that petitioner is not liable for an addition to tax under sec. 6661 for its year ended June 30, 1987.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011