- 8 - its employees including $125,000 in bonuses. Petitioner deducted these amounts as salaries and wages paid to its employees on its Forms 1120 in the fiscal years at issue. Petitioner did not maintain a compensation policy for its officers and employees. However, all 12 of petitioner’s memorandums of consent to corporate action from FYE June 30, 1985 through 1996, indicated Mr. Reeves received less than full and adequate compensation for his role as petitioner’s president and that petitioner would give future consideration to increasing Mr. Reeves’s salary and/or award future discretionary bonuses to reimburse him for his past and present service. The bonuses Mr. Reeves and petitioner’s other employees received were not based upon a formula or previously set forth in writing. Each bonus was determined and paid at the end of the fiscal year when petitioner could ascertain its cash availability and determine what would be a reasonable bonus, taking into consideration previous underpayments. E. Advertising Agreement With UMI In the fiscal year previous to UMI’s formation, petitioner’s gross skin care and tanning products sales totaled $600,000 with $124,000 profit. In an effort to increase sales, in June 1995 (in petitioner’s FYE June 30, 1995), petitioner entered into an agreement with UMI by which, in exchange for $1 million, UMI agreed to brand, market, and advertise the skin care and tanningPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007