- 26 -
should report under each of the different methods of accounting.8
Respondent has conceded $226,170 of the difference in the amount
of income for 1990. Other than documents pertaining to the
$226,170 conceded by respondent, petitioner did not put on any
evidence nor make any arguments on brief concerning the remaining
differences. We treat this as a concession by petitioner and
Mrs. Wang, and find for respondent.
Issue 2. Reasonable Compensation
Section 162(a)(1) provides for a deduction for ordinary and
necessary business expenses including "a reasonable allowance for
salaries or other compensation for personal services actually
8The fourth stipulation of settled issues sets forth the
following amounts as income from real estate sales under the
accrual method:
Income to Be Reported by Petitioners Mr. & Mrs. Wang
(Per Petitioners' Computations)
Year Accrual Method
1990 $663,739
1991 168,545
1992 -0-
Post-92 -0-
Income To Be Reported by Petitioners Mr. & Mrs. Wang
(Per Respondent's Computations)
Year Accrual Method
1990 $716,239
1991 183,141
1992 -0-
Post-92 -0-
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