- 2 - its carryback of losses from 1991, 1992, and 1993, P's deficit in retained earnings on Dec. 31, 1993, was $1,463,768. Held: R did not conduct a second examination of P's books of account in violation of sec. 7605(b), I.R.C. Held, further, sec. 162(a)(1), I.R.C., allows P to deduct $1,750,000 in 1993 as reasonable compensation paid to A. Gordon S. Gold, David J. Lieberman, and Barry R. Bess,1 for petitioner. Trevor T. Wetherington and Robert D. Heitmeyer, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Petitioner petitioned the Court to redetermine an income tax deficiency of $546,634 for 1990. The deficiency stems from respondent's determination that petitioner may not deduct $1,750,000 paid to its shareholder/employee in 1993 reportedly as compensation. Petitioner reported a net operating loss (NOL) for 1993 that it carried back to 1990. We must decide the following issues: 1 At the start of trial, the Court allowed Mr. Bess to withdraw as counsel because he was going to be a witness for petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011