- 5 - fiscal year ended July 31, 1994. OPINION Issue 1. Deduction for Compensation Not Paid by Petitioner During Its Fiscal Year Section 2671 requires the matching of deductions and income between related taxpayers. It provides that the payor may not deduct an obligation owing to a related payee until the related payee would be required to recognize the income by reason of his method of accounting. Sec. 267(a)(2). Doyce Gentry is petitioner’s sole shareholder. Mr. Gentry is therefore related to petitioner under section 267(a)(2)(B). See sec. 267(b)(2). In addition, Doyce Gentry’s stock ownership is attributed to his sons because they are his lineal descendants. See sec. 267(b)(1), (c)(2), (c)(4). Doyce Gentry’s sons therefore are also related to petitioner for purposes of section 267(a)(2)(B). Respondent denied petitioner’s deduction of $100,000 in accrued compensation under section 267(a)(2) because petitioner is an accrual method taxpayer, Doyce Gentry and his sons are cash method taxpayers, and the compensation was not actually paid by petitioner to the Gentrys by the close of petitioner’s fiscal year on July 31, 1994. 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011