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or employee may actually be an examination of the corporation's
books because of the inextricable identity between them or
because examination of the individual's books serves as a
subterfuge for examining the corporation's books; e.g., where the
separate accounts are all maintained in the same volume. Compare
Reineman v. United States, 301 F.2d 267 (7th Cir. 1962), and
Application of Leonardo, 208 F. Supp. 124 (N.D. Cal. 1962), with
Hall v. Commissioner, 50 T.C. at 201-202, and United States
Holding Co. v. Commissioner, 44 T.C. 323, 327-328 (1965). The
record at hand, however, lacks the requisite evidentiary
foundation to persuade us that any examination of Mr. Ashare's
books of account was a subterfuge for examining petitioner's
books. The record merely suggests that the revenue agent simply
did what he purported to do; namely, gather information on the
potential personal income tax liability of Mr. Ashare, a taxpayer
who, although related to petitioner, is separate and distinct
from it. See United States Holding Co. v. Commissioner, supra.
We turn to the primary issue; namely, whether section 162(a)
allows petitioner to deduct the $1,750,000 paid to Mr. Ashare as
compensation. A payment of compensation is deductible under that
section if it is reasonable in amount and for services actually
rendered to the payor in or before the year of payment. See sec.
162(a)(1); Lucas v. Ox Fibre Brush Co., 281 U.S. 115, 119 (1930);
Alpha Med., Inc. v. Commissioner, 172 F.3d 942, 945 (6th Cir.
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