Your client, Hoosier Corporation, is owned by two shareholders: Amy and Max. At year-end 2019, the company accountant determined Amy was due a bonus payment for performance in the amount of $50,000. The company accountant also determined Max was owed $25,000. The bonuses are paid according to a complex formula dependent upon hours of contributed service. Max believes his hours were not properly accounted for and has refused to take receipt. The company accountant has refused to issue the checks to both shareholders until a reconciliation can be reached. The company has properly accrued the two amounts on its books as a deduction for financial reporting purposes.

Prepare a research memo for your firm's file addressing the following two issues: First, do the two shareholders have to include the bonus payments in their income on their personal tax returns? See Bones v. Commissioner, 4 T.C. 415, 420 (1944); and Griffith v. Commissioner, 35 T.C. 882, 891 (1961). Second, in the event the taxpayers did not include the bonus payments in income, can the corporation take a deduction under Internal Revenue Code section 267?

Write a letter to your client (use the Tax Research Letter Template provided.)