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multiple roles in managing petitioner’s operations.
Petitioner’s jobs did not require substantial scientific and
highly technical knowledge. Miller Box, Inc. v. United States,
488 F.2d 695, 705 (5th Cir. 1974) (wooden ammunition box
manufacturing operation was simple); Tricon Metals & Servs., Inc.
v. Commissioner, T.C. Memo. 1997-360; cf. Choate Constr. Co. v.
Commissioner, T.C. Memo. 1997-495 (taxpayer specialized in
constructing complex projects such as hospital operating rooms,
robotics facilities, high-quality glass-making plants, and
industrial “clean rooms”).
This factor favors respondent, but the advantage to
respondent is substantially offset by the leanness of
petitioner’s management team and the multiple functions Mr. and
Mrs. Myers performed in managing petitioner’s operations. See
PMT, Inc. v. Commissioner, T.C. Memo. 1996-303 (noting that
courts have considered the recipient-employee’s performance of
more than one function for the employer); see also Labelgraphics,
Inc. v. Commissioner, T.C. Memo. 1998-343, affd. 221 F.3d 1091
(9th Cir. 2000).
D. Comparison of Mr. and Mrs. Myers’s Salaries and Bonuses
With Petitioner’s Gross Receipts and Net Income or Net
Loss After Taxes
Although it is often helpful to consider compensation as a
percentage of both gross receipts and net income, net income is
usually more important, because it more accurately gauges whether
a corporation is disguising the distribution of dividends as
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