- 32 - The $500,000 Bonus Paid in 1990 In EIC's notice of deficiency for 1990, respondent dis- allowed a deduction for the $500,000 bonus paid to petitioner at yearend. Respondent argues on brief that the bonus was excessive and therefore not deductible as reasonable compensation under section 162(a). EIC responds that petitioner, a key employee at EIC, was instrumental in the corporation's success and entitled to higher compensation. EIC therefore concludes that the bonus was reasonable and fully deductible. We agree with EIC that petitioner played an important role in the corporation's financial success. Petitioner was a central figure in managing the corporation and worked long hours to increase its business. Nevertheless, on the basis of the record before us, we are unable to conclude that EIC has successfully demonstrated that the bonus was reasonable in amount. EIC has not related the bonus to any duties performed by petitioner. The record indicates that petitioner's administra- tive functions with respect to EIC remained constant throughout the years at issue, while petitioner's 1990 salary of $283,200 exceeded the salary he received in other years. Thus, the bonus did not serve to compensate petitioner for any unusual activities in connection with his administrative functions. Additionally, no evidence was presented, nor any argument made, that this bonus was derived from specific sales generated by petitioner.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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