- 10 - reported to his father, Lynn. We concluded that T.D. Lynn's compensation was reasonable, and we took his duties into account when we determined the amount of reasonable compensation for the other officers. Respondent's expert, David J. Bowering, also took those factors into account in multiplying the compensation paid to the Daedalus CEO by 150 percent, and we took the multiple roles into account in determining reasonable compensation for Lynn. We do not agree with petitioner that the salaries of two separate officers should be both combined and doubled, because to do so would be to duplicate the adjustment that we previously made. Petitioner refers to losses sustained by Daedalus in earlier years in support of its argument. Petitioner, however, also had meager and loss years. We recognized in our prior opinion and recognize now the contributions that Lynn made to the success of petitioner. As the court stated in Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d 1315, 1325 (5th Cir. 1987), affg. T.C. Memo. 1985-869, "limits to reasonable compensation exist even for the most valuable employees." Upon our review of the entire record and with careful consideration of the opinion of the Court of Appeals, we believe that we made the appropriate allowances on the evidence in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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