- 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