- 56 - services. Mr. Podd testified that Plus provided Powertex services in the nature of "general guidance" and "direction". More specifically, it was Mr. Podd's uncontroverted testimony that Plus reviewed sales invoices and entertained customers of Powertex. Respondent contends that the fees paid to Plus are not deductible because they lacked a business purpose and because Plus was merely a holding company which failed to provide any significant services to Powertex. Respondent does not argue that the management fee payments were not reasonable. At trial, petitioners offered credible testimony that significant services were provided to Powertex through Plus. On the record before us, we hold that the payments made by Powertex to Plus as management fees during the years in issue were for services actually rendered and that, therefore, they are deductible under section 162. IV. Issue 4: Whether Individual Petitioners Received Constructive Dividends FINDINGS OF FACT Respondent determined that the Podds and Mrs. Podd received constructive dividends from a variety of sources.14 14 On brief, respondent concedes that Mr. Podd did not receive dividend income of $2,749,501 from his constructive receipt of the Amoco patents from Powertex via the granting of patent rights in his name during 1989. Petitioners conceded some of the items of dividend income in the stipulations of facts. The only items (continued...)Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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