- 57 - a COO. Therefore, on the basis of the data that we have found reliable for other companies in the industry contained in Mr. Reilly's report, we find that for both years in issue at least $385,000 is reasonable compensation for Dennis as CEO and at least $250,000 is reasonable for Curtis as COO. 6. Petitioner's Compensation Policy for All Employees Courts have considered the taxpayer's compensation policy for its other employees in deciding whether compensation is reasonable. See Mayson Manufacturing Co. v. Commissioner, 178 F.2d at 119; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. at 1159. This factor focuses on whether the entity pays top dollar to all employees, including both stockholders and nonstockholders. See Owensby & Kritikos, Inc. v. Commissioner, supra at 1329-1330. We look to this factor to determine whether Dennis and Curtis were compensated differently than petitioner's other employees merely because of their status as stockholders. See id. Petitioner paid its employees the highest wages under the union contracts. That fact, along with petitioner's success, supports paying Dennis and Curtis the highest salaries for officers. The salaries paid to Dennis and Curtis were substantially lower than the compensation paid to top executives of other companies. This supports a finding that part of the bonus was compensation for services rendered during the year.Page: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 Next
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