- 32 - bonus for his efforts in successfully developing the Micro Clean 100 process. This $406,000 of reasonable compensation, we estimate, results in a revised return on equity for petitioner of approximately 10.20 percent for the 1990 fiscal year.7 We think an independent investor would be satisfied with this return on equity and with petitioner's 1990 fiscal year financial performance. Despite the slight decline in business experienced for that year, Mr. Martin still had done an excellent job in managing petitioner. As previously discussed, petitioner was encountering increased competition in the Portland market and was experiencing some loss of sales due to its customers' relocating their manufacturing facilities overseas. Moreover, petitioner 7Petitioner's organizational minutes provide that if the Internal Revenue Service or a court of competent jurisdiction determines any "salary to any stockholder officer" to be a dividend, the payment shall immediately be treated as a loan to the officer (with interest payable at the legal rate from the date of payment thereof), due and payable within 1 year from the date of determination. If Mr. Martin's total compensation was $406,000, rather than $878,913, petitioner's 1990 fiscal year income would be increased $472,913, giving it a revised net income before taxes of $320,274 (the ($152,639) net loss reflected on the 1990 fiscal year financial statement, plus $472,913). Assuming combined Federal and State income taxes are imposed equal to 40 percent of this revised net income before taxes, petitioner's revised net taxable income after taxes would be $192,164 ($320,274 multiplied by 60 percent) and its revised equity would be $1,884,143 (revised retained earnings, plus invested capital, less treasury stock, per 1990 fiscal year financial statement). This would represent a revised return on equity of approximately 10.20 percent ($192,164 divided by $1,884,143).Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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