- 2 -
The issue for decision is whether petitioner may deduct as
officer compensation paid to Dennis Wagner (Dennis) and Curtis
Wagner (Curtis) for taxable years ending October 31, 1995 and
1996, the amounts shown below as the parties contend, or some
other amounts:
Petitioner
Year Dennis Curtis Total
10/31/95 $1,048,200 $246,688 $1,294,888
10/31/96 699,192 400,573 1,099,765
Respondent
Year Dennis Curtis Total
10/31/95 $243,000 $192,450 $435,450
10/31/96 258,600 202,350 460,950
Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended and in effect for the years
in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
A. General Background
Petitioner is a Minnesota corporation that was incorporated
on November 1, 1985. When the petition in this case was filed,
petitioner maintained its principal place of business in
International Falls, Minnesota.
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