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Adjustments
For the fiscal years in issue, the following table shows the
amounts petitioner claimed as deductions for compensation paid to
Mr. Wechsler, Mrs. Wechsler, and Gilbert and the amounts
respondent allowed:
Mr. Wechsler
Year Amount claimed Amount allowed Amount disallowed
1992 $4,390,000 $1,834,000 $2,556,000
1993 4,890,000 1,486,000 3,404,000
1994 7,090,000 3,665,927 3,424,073
1995 5,860,000 2,414,067 13,445,933
1996 5,390,000 2,316,344 3,073,656
1997 1,390,000 1,176,000 214,000
1998 7,487,000 3,821,000 3,666,000
1999 1,494,771 1,035,000 459,771
1 In the stipulation of facts, the amount of Mr. Wechsler’s
compensation that was disallowed as a deduction for the 1995
fiscal year is stated to be $3,445,993. In the notice of
deficiency, that amount is stated to be $3,445,933. We assume
that the $60 difference is due to the parties’ error in drafting
the stipulation. We accept the amount disallowed in the notice
of deficiency as correct.
Mrs. Wechsler
Year Amount claimed Amount allowed Amount disallowed
1999 $486,154 $150,000 $336,154
Gilbert
Year Amount claimed Amount allowed Amount disallowed
1992 $80,359 -0- $80,359
1993 108,097 -0- 108,097
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