- 12 - In 2002, Mr. Reeves sold his residence in Newberg, Oregon, as part of a bankruptcy sale. As part of the sale, petitioner sold the floating structures to Mr. Reeves’s wife’s company, Royal Sun Properties, L.L.C., for $100,000 with $55,000 paid as a downpayment.12 Respondent issued the notice of deficiency on March 8, 2002. Petitioner timely filed its amended petition on August 19, 2002. OPINION I. Reasonable Compensation Petitioner contends the amounts paid to its sole executive and shareholder, Mr. Reeves, in the fiscal years at issue constituted reasonable compensation under section 162(a)(1). Conversely, respondent contends Mr. Reeves’s compensation for the fiscal years at issue was unreasonable but, on the basis of respondent’s expert’s opinion, concedes deductions of $1 million and $750,000,13 respectively. 12 Royal Sun Properties, L.L.C., still owes petitioner $45,000. 13 The $750,000 includes reasonable compensation paid to Mr. Reeves by petitioner and UMI together. Respondent argued on brief that if the Court accepted $750,000 as reasonable compensation for FYE June 30, 1996, it would be appropriate to divide this amount between petitioner and UMI and allow petitioner to deduct $499,012. Respondent alternatively argued that it would be appropriate to allow UMI its full claimed deduction of $509,000 if petitioner were allowed only $250,000 as reasonable compensation for its FYE June 30, 1996.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007