O.S.C. & Associates, Inc., D.B.A. Olympic Screen Crafts v. Commissioner of Internal Revenue

187 F.3d 1116, 99 Cal. Daily Op. Serv. 6576, 23 Employee Benefits Cas. (BNA) 1569, 99 Daily Journal DAR 8427, 84 A.F.T.R.2d (RIA) 5735, 1999 U.S. App. LEXIS 18880
CourtCourt of Appeals for the Ninth Circuit
DecidedAugust 16, 1999
Docket97-71199
StatusPublished
Cited by13 cases

This text of 187 F.3d 1116 (O.S.C. & Associates, Inc., D.B.A. Olympic Screen Crafts v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O.S.C. & Associates, Inc., D.B.A. Olympic Screen Crafts v. Commissioner of Internal Revenue, 187 F.3d 1116, 99 Cal. Daily Op. Serv. 6576, 23 Employee Benefits Cas. (BNA) 1569, 99 Daily Journal DAR 8427, 84 A.F.T.R.2d (RIA) 5735, 1999 U.S. App. LEXIS 18880 (9th Cir. 1999).

Opinions

SILVERMAN, Circuit Judge:

A corporation’s payment of compensation to employees is tax deductible by the corporation; its payment of dividends to shareholders is not. In this ease, we once again examine the circumstances under which deductions for payments to shareholder-employees of a closely-held corporation, ostensibly as compensation for services, will be disallowed as disguised dividends. In Elliotts, Inc. v. Commissioner, 716 F.2d 1241 (9th Cir.1983), we applied a two-part test to deter[1118]*1118mine the deductibility of such payments: reasonableness of amount and compensatory intent. We said, “In the rare case where there is evidence that an otherwise reasonable compensation payment contains a disguised .dividend, the inquiry may expand into compensatory intent apart from reasonableness.” Id. at 1244.

This is such a case. We affirm the tax court’s finding that OSC’s payments to Blazick and Richter, whether or not reasonable in amount, were not intended as compensation. They were dividends in disguise.

FACTUAL AND PROCEDURAL BACKGROUND

In 1970, Allen Blazick bought a silk-screening business for $180.00. He and his wife operated the business on a part-time basis from their two-bedroom apartment while he continued to go to school and work at a bank during the day. As the business grew, Blazick hired Steven Richter, his brother-in-law, to assist with manufacturing. He was paid $2.00 per hour when they could afford it. In 1976, Blazick and Richter’s enthusiasm, energy and hard work started to pay off — Blazick landed Safeway Stores as a client. It is undisputed that Blazick and Richter continued to bring their extraordinary talent, dedication, and energy to the business, and it is undisputed that the business prospered remarkably as a direct result of their personal efforts. By 1991, Olympic Screen Crafts had moved from Blazick’s kitchen table to a 65,000 square-foot plant, had over 200 employees, and grossed over $13 million a year.

In 1982, the business was incorporated. Blazick became OSC’s President and Chief Executive Officer, and owned 90% of its stock; Richter became OSC’s Vice President, and was issued the remaining 10% of its stock. Blazick’s wife served as the secretary and treasurer.

Three years after OSC incorporated, it adopted an incentive compensation plan. According to OSC, its purpose was “to recognize and compensate Blazick and Richter for their distinct and different contributions to the business.” The incentive plan was developed by Leo Rosi, Blazick’s college acquaintance and OSC’s long-time certified public accountant. Blazick and Richter were the plan’s only participants. Under the terms of the plan, the amount of incentive compensation was to be determined at the end of each fiscal year by first calculating a hypothetical gross margin. The gross margin was calculated by multiplying OSC’s actual total sales by an adjusted industry gross margin ratio. The total incentive compensation pool consisted of the difference between OSC’s actual gross margin and the hypothetical adjusted industry gross margin.

The plan expressly provided that payments from the incentive compensation pool would be made “according to stock ownership.” It directed that after specific deductions were taken from each participant’s share, 90% of the total incentive compensation pool would be allocated to Blazick, with the remaining 10% going to Richter. Each year, Blazick’s incentive compensation was to be reduced by any inventory shortages in excess of $100,000 and by any bad debts. Likewise, Richter’s incentive compensation was to be reduced by. inventory spoilage in excess of $100,000 and production costs in excess of $100,000. As a practical matter, this formulation resulted in the corporation distributing nearly all (between 82% and 94%) of its net income as incentive payouts to Blazick and Richter in the years in question. All of the incentive compensation paid out to Blazick and Richter was deducted as compensation under § 162(a) of the Internal Revenue Code. The IRS disallowed a sub[1119]*1119stantial portion of those deductions.1

As the company’s accountant, Rosi performed the hands-on implementation of the plan. He acknowledged that the method he used to calculate the corporation’s cost of goods sold was not in accordance with generally accepted accounting principles. He also testified that in 1990 and 1991, he “miscalculated” OSC’s gross profits resulting in an arbitrary increase to the incentive compensation pool. He also acknowledged his failure to make other adjustments required by the plan, thus increasing the distributions to Blazick and Richter.

OSC never paid or declared a dividend, despite the fact that in 1988 or 1989, the years immediately following the incentive plan’s implementation, Rosi specifically advised OSC to pay them. Rosi testified that Blazick was strongly opposed to the idea. Rosi testified that because of Blaz-ick’s reaction to his advice, he never brought it up again. Blazick’s antipathy to dividends also was reflected in a credit memorandum prepared by an officer of Union Bank in 1992. It contained the following statement:

[Blazick’s] salary for 1991 was over $1.8MM. The reasoning behind the higher salary is taxable income. Mr. Blazick does not intend to be taxed twice for the profitability of his business. He contends taking the higher salary will increase his personal tax liability, but this rate is lower than the corporate tax rate.

For each of the tax years in issue, OSC deducted the full amounts paid to Blazick and Richter under the incentive plan. The IRS disallowed most but not all of it. The IRS assessed back taxes on the disallowed amounts and assessed an accuracy-related penalty pursuant to 26 U.S.C. § 6662(a).2

At trial before the Tax Court, OSC offered considerable evidence of Blazick and Richter’s extraordinary hard work and unique skills, and of the corporation’s phenomenal growth and better-than-average performance due to their personal efforts. Nevertheless, the Tax Court found that the plan allocations were not made with compensatory intent. It found that the plan “was both designed and manipulated to direct the flow of corporate earnings to Messrs. Blazick and Richter and to disguise such payments as compensation.” On that basis, it also upheld the imposition of a penalty for negligence.

I Deductibility of Compensation

Section 162(a)(1) of the Internal Revenue Code permits a corporation to deduct “a reasonable allowance for salaries or other compensation for services personally rendered.” 26 U.S.C. § 162(a)(1). The payment of dividends to shareholders, however, is not deductible. When pay[1120]*1120ments are made to an individual who is both a corporate employee and a principal shareholder, a two-prong test is applied to determine whether the distribution is truly compensatory. First, the amount of compensation must be reasonable; second, the payment must be purely for services, or have a purely compensatory purpose. Elliotts, 716 F.2d at 1243; Nor-Cal Adjusters v. Commissioner,

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Bluebook (online)
187 F.3d 1116, 99 Cal. Daily Op. Serv. 6576, 23 Employee Benefits Cas. (BNA) 1569, 99 Daily Journal DAR 8427, 84 A.F.T.R.2d (RIA) 5735, 1999 U.S. App. LEXIS 18880, Counsel Stack Legal Research, https://law.counselstack.com/opinion/osc-associates-inc-dba-olympic-screen-crafts-v-commissioner-of-ca9-1999.