Chen C. and Victoria R. Wang, et al. - Page 27

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          rendered".  To fall within the ambit of section 162(a)(1), the              
          compensation must be both reasonable in amount and paid purely              
          for services.  Sec. 1.162-7(a), Income Tax Regs.  Typically, the            
          deductibility of compensation turns on whether the compensation             
          paid is reasonable in amount.  Elliotts, Inc. v. Commissioner,              
          716 F.2d 1241, 1243-1244, (9th Cir. 1983), revg. and remanding              
          T.C. Memo. 1980-282.  EIC bears the burden of proving the reason-           
          ableness of compensation.  Rule 142(a).                                     
               The reasonableness of compensation is a question of fact to            
          be determined on the basis of all the facts and circumstances.              
          Pacific Grains, Inc. v. Commissioner, 399 F.2d 603, 606 (9th Cir.           
          1968), affg. T.C. Memo. 1967-7.  Many factors are considered in             
          determining whether compensation is reasonable, and no single               
          factor is decisive.  Mayson Manufacturing Co. v. Commissioner,              
          178 F.2d 115, 119 (6th Cir. 1949), revg. a Memorandum Opinion of            
          this Court.  In Elliots, Inc. v. Commissioner, supra at 1245-               
          1248, the Court of Appeals for the Ninth Circuit, the Court to              
          which these cases are appealable, arranged these factors into               
          five broad categories.                                                      
               The first factor focuses on the employee's responsibilities            
          and duties in the organization.  Relevant considerations include            
          petitioner's qualifications, hours worked, duties performed, as             
          well as his importance to EIC's success.  American Foundry v.               
          Commissioner, 536 F.2d 289, 292 (9th. Cir. 1976), affg. in part             





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