IRS Falters Under Elliotts' ‘Five Factors’ Test for Reasonable Compensation

Business Valuation UpdateVol. 13 No. 11
Legal and Court Case Update
November 2007

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5499 Miscellaneous Food Stores
446191 Food (Health) Supplement Stores
Vitamin Village, Inc. v. Commissioner
2007 Tax Ct. Memo LEXIS 278
September 12, 2007
US
Federal Court
United States Tax Court
Wesley F. McNamara
Scott Hakala (IRS)
Haines

Summary

Taxpayer justifies reasonable compensation of key executive under Elliotts five-factor analysis, including “independent investor” test focusing on returns on equity.

See Also

Vitamin Village, Inc. v. Commissioner

Full Text of Court Cases
September 12, 2007

Taxpayer justifies reasonable compensation of key executive under Elliotts five-factor analysis, including “independent investor” test focusing on returns on equity.