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International equaled $400,000, consisting of the stated salary
of $150,000 and the salary bonus of $250,000 -- approximately 60
percent of the annual salary Meyer received in 1988 and 1989.
We conclude that the $245,905 paid to Meyer for 1990 and the
$250,000 paid to Meyer for each of the years 1991 and 1992 as a
salary bonus should be treated as reasonable compensation paid to
Meyer for services he rendered to International and as currently
deductible ordinary and necessary business expenses.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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