- 17 - Petitioner argues that, during the audit years, Mrs. Harrison provided significant services to petitioner consisting principally of (1) her services as a member of petitioner’s board of directors, (2) her public relations activities, i.e., her activities as petitioner’s primary representative at numerous charitable and civic events in the communities served by petitioner, and (3) her personal guaranty of the line of credit to petitioner from Bank of America. Petitioner also argues that its return on equity during the audit years would have satisfied an independent investor in petitioner. On that basis, petitioner argues that it is entitled to deduct the entire amount paid to Mrs. Harrison during the audit years as reasonable compensation for services rendered. C. Analysis 1. Applicable Caselaw Because petitioner’s principal place of business is in California, it is likely that any appeal of this case would be to the Court of Appeals for the Ninth Circuit. See sec. 7482(b)(1)(B). Therefore, we must apply that court’s jurisprudence governing issues of reasonable compensation in accordance with the doctrine of Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. 1971). 2(...continued) forth in Nor-Cal Adjusters v. Commissioner, 503 F.2d 359, 361-362 (9th Cir. 1974), affg. T.C. Memo. 1971-200.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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