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Steven Klein relied on Richard Schwaeber to advise
petitioner about the amount of compensation it could reasonably
pay him in 1995. Richard Schwaeber told Steven Klein that a
salary of about $800,000 in 1995 would be reasonable. We hold
that petitioner’s reliance on Richard Schwaeber was reasonable
cause for deducting the compensation it paid to Steven Klein in
1995.
We conclude that petitioner is liable for the accuracy-
related penalty under section 6662 for 1993 and 1994, but it is
not liable for 1995.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
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