- 2 - After concessions,2 the issues for decision are: (1) Whether the amounts paid to petitioner’s sole executive and shareholder during the fiscal years at issue constituted reasonable compensation under section 162(a)(1); (2) whether petitioner is entitled to deduct advertising expenses under section 162(a) of $1,105,276 for FYE June 30, 1996; and (3) whether petitioner is entitled to depreciate costs incurred in constructing a houseboat, a floating garage, and a dock under section 167(a)(1) during the fiscal years at issue. FINDINGS OF FACT The parties’ stipulation of facts and the attached exhibits are incorporated herein by this reference, and the facts stipulated are so found. At the time the petition was filed, petitioner maintained its business office in Wilsonville, Oregon. A. Petitioner’s Business History Petitioner was incorporated by Daniel L. Reeves in the State of Oregon in 1979.3 Petitioner, an accrual basis taxpayer with 1(...continued) the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. Amounts are rounded to the nearest dollar. 2 At trial, respondent conceded that petitioner was entitled to deduct a net operating loss of $320,845 in FYE June 30, 1996, carried back from its FYE June 30, 1998. On brief, petitioner conceded it failed to report interest income of $11,516 in FYE June 30, 1996. 3 Mr. Reeves originally founded petitioner with two other (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007