Chen C. and Victoria R. Wang, et al. - Page 31

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          For each sale, the schedule allocates the commissions among the             
          various salespeople, including petitioner.  While not clear, it             
          appears that the schedule is produced from information contained            
          in EIC's general ledger accounting program.  The schedule does              
          not provide a summary of the total commissions paid to each                 
          individual salesperson, but when added together, all of peti-               
          tioner's individual commissions for 1989 amounted to $506,986.              
          Near the bottom of the schedule, there are journal entries                  
          totaling $901,428, the amount actually paid to petitioner.  The             
          journal entries, made at year end, do not reference any particu-            
          lar sales (as all the other entries do), but instead contain the            
          notations "all sales override" or "withdraw".  No explanation for           
          these entries was given at trial.                                           
               On brief, EIC has not put forth any arguments concerning               
          compensation paid to petitioner in 1989 other than to assert that           
          the commissions were reasonable because they related to specific            
          sales.  As previously noted, no evidence was presented at trial,            
          nor was any argument made on brief, concerning the journal                  
          entries totaling $901,428.  Accordingly, based on the entire                
          record before us, we conclude that $506,986 represents a reason-            
          able amount of compensation to petitioner for his efforts in                
          selling land for EIC in 1989.                                               








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