Reasonable Compensation Analysis Ignores Objective Evidence, Tax Court Says

BVLaw
Court Case Digests
November 23, 2016
5099 Durable Goods, NEC
423990 Other Miscellaneous Durable Goods Merchant Wholesalers
federal taxation
expert testimony, normalization, reasonable compensation, closely held corporation, fraud, comparable, officer compensation

Transupport, Inc. v. Commissioner
2016 Tax Ct. Memo LEXIS 214
US
Federal Court
Federal
United States Tax Court
Stephen Kirkland (taxpayer/petitioner); Frank J. Wojick, Jr., Gregory Scheig (IRS/respondent)
Cohen

Summary

Tax Court dismisses taxpayer expert’s reasonable compensation analysis as not helpful to trier of fact; court points to failure to consider objective evidence and detects willingness to “validate and confirm” the amounts reported on taxpayer’s returns.

See Also

Transupport, Inc. v. Commissioner

Tax Court dismisses taxpayer expert’s reasonable compensation analysis as not helpful to trier of fact; court points to failure to consider objective evidence and detects willingness to “validate and confirm” the amounts reported on taxpayer’s returns.

Reasonable Compensation Analysis Ignores Objective Evidence, Tax Court Says

Tax Court dismisses taxpayer expert’s reasonable compensation analysis as not helpful to trier of fact; court points to failure to consider objective evidence and detects willingness to “validate and confirm” the amounts reported on taxpayer’s returns.