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Respondent determined the amount of petitioner’s allowable
deductions for reasonable compensation by use of statistics
reflecting compensation for corporate officers in the equipment-
leasing and real estate-rental business. Based on those
statistics, respondent determined that petitioner was entitled to
a deduction of $76,800 for each of the years 1995 and 1996 as
reasonable compensation for the Valentes’ services to petitioner.
The following schedule reflects respondent’s comparison
between petitioner’s taxable income; adjusted taxable income
(adjusted to not include net operating loss deductions, special
deductions, and deductions for officer’s compensation); officer’s
compensation; and the percentage of adjusted taxable income
represented by officer compensation:
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