WSB Liquidating Corporation - Page 11

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          that Barbara was overcompensated for her services, at least from            
          1984 until May 1, 1989, during which period her weekly salary               
          increased significantly notwithstanding the substantial                     
          curtailment of her responsibilities and time spent at the office.           
          In the absence of corroborating evidence, we accord little weight           
          to the self-serving recitals in the Pension Agreement.  See,                
          e.g., Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                      
               We are similarly unimpressed with petitioner’s argument that           
          its business interests were served by providing a monetary                  
          inducement for Barbara to retire because her office presence had            
          become disruptive.  If an employee interferes with the efficient            
          operation of an employer’s business, we do not find it plausible            
          that the employer would “induce” the employee to retire with an             
          offer of full salary for life, adjusted for inflation.  The                 
          provisions connected with the termination of Barbara’s services             
          for petitioner make considerably more sense when placed in the              
          context of Barbara’s status as (1) the estranged former spouse of           
          petitioner’s controlling shareholder and (2) the probable holder            
          of a significant equitable interest in petitioner, by virtue of             
          her property rights arising from the marital relationship and/or            
          her contributions as a cofounder to petitioner’s success.                   
               This is not to suggest that the characterization of the                
          payments by petitioner to Barbara is based on mere speculation.             
          We believe the Settlement Agreement, which is clearly                       

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