AN EMPIRICAL ANALYSIS OF THE TAX COURT'S DETERMINATION OF REASONABLE COMPENSATION
建立多元回归模型预测税务法院允许的薪酬占争议金额的比例，发现纳税人通常获得有利裁决，模型对制定上诉策略有参考价值。
ABSTRACT The determination of reasonable compensation is one of the most frequently contested issues between the taxpayer and the IRS. The major purpose of this study is to develop a multiple regression model to predict accurately the amount of compensation allowed by the Tax Court as a percent of the amount in dispute between the taxpayer and the IRS. In general, the taxpayer receives favorable treatment in Tax Court when contesting unreasonable compensation payments. The multiple regression model, developed using a stepwise procedure, is a good predictor of the compensation allowed by the court. The overall results have important implications for developing taxpayers' appeal strategies.