- 5 - incorporation on August 9, 1985. Petitioner issued shares of its stock to the trust in payment of the contributions to the trust. Robert and Charlene Peers were, during the taxable years that ended July 31, 1987, through 1990, and are the founders and sole officers of petitioner. Robert Peers was and is its president, and Charlene Peers was and is the trustee of the ESOP's trust. Robert and Charlene Peers also have been the only participants in the ESOP. Petitioner reported the following deductions on its U.S. Corporation Income Tax Returns, Forms 1120: Pension Compensation Salaries Profit-sharing, of Officers and Wages etc., plans Year (Line 12) (Line 13) (Line 24) 1987 $0 $801.01 $45,000 1988 0 0 17,000 1989 0 0 10,050 1990 0 0 9,870 The deductions for "Pension, Profit-sharing, etc., plans" were reflected as contributions to the trust in the trust's Forms 5500-C, Return/Report of Employee Benefit Plan, for each of such years. In addition, petitioner included the following commissions, paid to nonemployees who were treated by petitioner as independent contractors, on line 26, "Other deductions":Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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