- 20 - salary was 88.45 percent of taxable net income (before deducting his compensation) in 1992 and 90.27 percent in 1993. 5. General Economic Conditions This factor helps to determine whether the success of a business is attributable to general economic conditions, as opposed to the efforts and business acumen of the employee. General economic conditions may affect a business' performance and indicate the extent (if any) of the employee's effect on the company. Adverse economic conditions, for example, may tend to show that an employee's skill was important to a company that grew during the bad years. Mad Auto Wrecking, Inc. v. Commissioner, supra. Petitioner has faced economic ruin and been forced to reinvent itself on at least three separate occasions. Its sales went from $1 million in its first year to $70 million in 1984. Sales fell to less than $1 million in 1985 and were back up to nearly $44 million by 1993. In 1984, petitioner lost its sales representation contract with Apple. This accounts for the precipitous sales decline in 1985. While petitioner represented Apple, it had developed Apple's four largest accounts nationwide. Herold devised a strategy of targeting these four largest accounts and selling other electronics products to them. He succeeded with three of these jumbo accounts. Just as that strategy was beginning to take hold, all three of these accounts ran into adverse economic conditions and became insolvent. Again, petitioner saw itsPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011