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Best Practices for Reasonableness of Employee Compensation Analysis

(Part III of III) Part one of this three-part series presented the description of Clary Hood, Inc. (“CHI”) and the description of the tax litigation concluded in the Hood decision. Part two of this series summarized the Tax Court’s analysis and conclusions regarding the reasonableness of executive compensation issues in this matter. This third and final discussion summarizes the Tax Court’s analysis and con ...

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Best Practices for Reasonableness of Employee Compensation Analysis

(Part I of III) This article about excess compensation is comprised of three-parts. Part one summarizes the facts regarding Clary Hood, Inc. v. Commissioner and the U.S. Tax Court’s holding. Part two of this series describes the Tax Court’s analysis and conclusions regarding the reasonableness of compensation issues. Part three describes the Tax Court’s analysis and conclusions regarding Section 6662 penalt ...

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