-19- Petitioner contends that it grew even though other independent claims adjusting companies failed. Nonetheless, petitioner benefited tremendously from the large amount of catastrophes (5 of the 10 largest in history) during its fiscal years 1992 and 1993. This factor favors respondent. 5. Petitioner's Financial Condition The past and present financial condition of a company is relevant to deciding whether compensation was reasonable. Home Interiors & Gifts, Inc. v. Commissioner, supra at 1157-1158. Petitioner contends that the fact that its gross receipts increased from $282,682 in fiscal year 1988 to $20,438,803 in fiscal year 1992 and $9,168,585 in fiscal year 1993 shows that its financial condition was good. We disagree. Petitioner's financial condition (in contrast to Eberl's) was poor. Despite having a large increase in gross receipts from fiscal year 1988 to fiscal years 1992 and 1993, petitioner had a tiny amount of profits in fiscal years 1992 and 1993, negative taxable income from fiscal years 1988 to 1992, and taxable income of only $27,393 in fiscal year 1993. Petitioner's profits in fiscal years 1992 and 1993 were substantially lower than those of comparably sized service companies. In Alpha Med., Inc. v. Commissioner, 172 F.3d 942 (6th Cir. 1999), revg. T.C. Memo. 1997-464, the taxpayer was a medical management corporation that paid its president and sole shareholder compensation of $4,439,180. The U.S. Court ofPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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