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Johnson as an officer of that company10 and that it did not pay
any compensation to Ms. Johnson as an officer. In that return,
G.E. Johnson, Inc., reported that it paid $38,082 of salaries and
wages, although it did not identify in that return the person or
persons to whom it paid those wages. In G.E. Johnson, Inc.’s
1993 return, G.E. Johnson, Inc., reported that it paid $145,628
in rent, although it did not specify in that return the amount of
such rent that it paid to petitioners during its taxable year
ended October 31, 1993.
In G.E. Johnson, Inc.’s 1994 return, G.E. Johnson, Inc.,
reported that it paid $1,000 of compensation to Mr. Johnson as an
officer of that company and that it did not pay any compensation
to Ms. Johnson as an officer. In that return, G.E. Johnson,
Inc., reported that it paid $43,544 of salaries and wages,
although it did not identify in that return the person or persons
to whom it paid those wages. In G.E. Johnson, Inc.’s 1994
return, G.E. Johnson, Inc., reported that it paid $122,014 in
rent, although it did not specify in that return the amount of
such rent that it paid to petitioners during its taxable year
ended October 31, 1994.
10As discussed above, petitioners’ 1993 return did not
report any wages or other compensation received from G.E. John-
son, Inc. Although not clear from the record, we presume that
G.E. Johnson, Inc., paid to Mr. Johnson sometime during the last
two months of 1992 the $20,000 of compensation that it reported
it paid to him as an officer during its taxable year ended Oct.
31, 1993.
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