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circumstances of each case. See Estate of Wallace v.
Commissioner, 95 T.C. 525, 553 (1990), affd. 965 F.2d 1038 (11th
Cir. 1992). Further, there are no fixed rules or exact standards
for determining what constitutes reasonable compensation. See
Golden Constr. Co. v. Commissioner, 228 F.2d 637, 638 (10th Cir.
1955), affg. T.C. Memo. 1954-221. With these rules in mind, we
determine whether the compensation Mr. Speltz received for
business-related services was reasonable in amount.
Mrs. Speltz recorded that Mr. Speltz worked 517.25 hours in
2000 and 655 hours in 2001. During those years, Mr. Speltz
received medical benefits of $3,279 and $4,255.58, respectively.
Mr. Speltz therefore received approximately $6.34 an hour in 2000
($3,279/517.25) and $6.50 an hour in 2001 ($4,255.58/655). Mr.
Speltz’s hourly rate is comparatively low considering the $13 an
hour that Mrs. Speltz testified she would have had to pay a
daycare substitute. Eliminating even half of Mr. Speltz’s hours
would produce a not unreasonable amount of compensation at $12.69
an hour in 2000 ($3,279/258.5) and $13.06 an hour in 2001
($4,255.58/325.75). Even assuming arguendo, therefore, that half
the hours Mrs. Speltz logged for Mr. Speltz were personal and
disallowable, we would nonetheless still find the compensation
provided Mr. Speltz in the years at issue reasonable in amount.
IV. Whether Petitioners May Deduct Insurance Premiums
In the alternative, respondent argues that the “insurance
premium” component of Mr. Speltz’s reimbursements is not
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