- 3 - 1. Whether respondent violated the prohibition of section 7605(b) against a second examination of petitioner's books of account for 1993. We hold he did not. 2. Whether section 162(a) allows petitioner to deduct the $1,750,000 as compensation. We hold it does. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the applicable years. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. FINDINGS OF FACT Some of the facts have been stipulated. The stipulation of facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioner is a corporate law firm that specializes in State and municipal employee pension benefits and the litigation thereof. It uses the cash method for Federal income tax purposes and an accrual method for book purposes. Its principal place of business was in Detroit, Michigan, when its petition was filed. Richard Ashare, an attorney, incorporated petitioner in 1974 with a capital contribution of $1,000. Mr. Ashare is petitioner's sole shareholder and one of its two employees. Petitioner's other employee is Mr. Ashare's secretary, Kathleen Moore Baker (Ms. Moore). Petitioner has three directors: Mr. Ashare, his wife, Marlene, and his longtime tax adviser, BarryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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