Frontier Custom Builders, Inc. v. Commissioner

PER CURIAM: *

This case arises from a tax dispute bet-tween Frontier Custom Builders, Inc. (Frontier) and the Commissioner of Internal Revenue over certain deductions that Frontier claimed for the 2005 tax year. The deductions were mostly comprised of employee salaries and year-end bonuses, including $1,318,000 in total compensation paid to the company’s founder, President, and CEO, Wayne Bopp. The Commissioner audited Frontier and determined that most of the salaries at issue should have been capitalized, instead of deducted, under the applicable tax rules, codified at 26 U.S.C. § 263A and…