Multi-Pak Corp. v. Comr., T.C. Memo. 2010-139

(CEO of petitioner can claim deduction for entire amount of compensation (slightly over $2 million paid by corporation in one year - amount reasonable for that year; but, partial deduction allowed for subsequent year - amount of compensation unreasonable because revenues fell and compensation not tied to corporate revenues; no accuracy-related penalty because accountant's bad advice reasonably relied upon). 

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