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cost and quantity of the gasoline and home heating oil which it
would purchase from Parker and, second, the price at which it
would sell those products to consumers. Whereas petitioner
(through Haff) set the price at which it would sell its products
to its customers, the record establishes that petitioner had few
negotiations with Parker as to petitioner’s cost of those
products. Petitioner also played no part in the negotiations of
the cost and quantity of those products purchased by Parker for
resale to petitioner. The negotiations, obviously, occurred
between Parker and the third party from which it purchased the
products. Although petitioner’s business could be viewed as
somewhat large in the sense that it employed approximately 150
individuals and generated approximately $60 million of gross
receipts, the fact of the matter is that petitioner’s business
was relatively small when compared to the industry’s “comparable”
businesses. As to both Emile and Louise, we answer the question
in the negative.
d. Comparison of Salaries Paid With Net and Gross Income
For each of the subject years, we compare Emile’s and
Louise’s compensation, including bonuses, first to petitioner’s
gross income and then to its taxable income (before any deduction
for the relevant employee’s compensation). As to Emile, the
first comparison yields percentages of 8.26, 7.55, and 7.23,
respectively, and the second comparison yields percentages of
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