Aries Communications Inc. & Subsidiaries v. Comr., T.C. Memo. 2013-97

(case involves reasonableness of compensation paid to radio executive; over his career in radio and television, executive started to buy radio stations and would become owner/operator/general manager; management style was active involvement overseeing personnel, oversight of programming, negotiating with lenders, participating in sales meetings and communicating with lawyers, accountants and others on behalf of company; ultimately, executive gave himself substantial bonus and company claimed associated deduction; issue was reasonableness of compensation and court gets into detailed mathematical computational process of experts of the parties; court set reasonable compensation level at amount higher than what IRS sought due primarily to executive being compensated for underpayments that occurred in prior years; deduction approximately one-third of amount paid to executive; 20 percent accuracy-related penalty imposed).