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(1) The employee's qualifications;
(2) the nature, extent, and scope of the employee's work;
(3) the size and complexities of the business;
(4) the prevailing general economic conditions;
(5) the prevailing rates of compensation for comparable
positions in comparable concerns;
(6) the salary policy of the taxpayer as to all employees;
(7) in the case of small corporations with a limited number
of officers the amount of compensation paid to the particular
employee in previous years;
(8) a comparison of salaries paid with the gross income and
the net income; and
(9) comparison of salaries with distributions to
stockholders.
We carefully scrutinize the facts at hand because Dennis
and Curtis, the employees to whom the compensation was paid,
control petitioner, the paying corporation. We must be sure that
any amounts purportedly paid as compensation were actually paid
for services rendered by Dennis and Curtis, rather than
distributions to them of earnings that petitioner could not
otherwise deduct. See Paul E. Kummer Realty Co. v. Commissioner,
511 F.2d 313, 315-316 (8th Cir. 1975), affg. T.C. Memo. 1974-44;
Charles Schneider & Co. v. Commissioner, supra at 152-153. No
single factor controls. We examine these factors from the
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