Questão jurídica principal
Whether the wages paid to the taxpayer's children were fully deductible business expenses.
Decisão extraída
Only part of the payments were deductible; the taxpayer failed to prove that the entire wage expense was exclusively business-related.
Fundamentação extraída
For self-employed persons, the taxpayer bears the burden of proving the business necessity of expense items. Under the arm's-length test, the decisive question is whether an independent third party would pay the same remuneration under the same circumstances. Given the small business's size, turnover, and the family relationship, the court accepted that the payments contained a support or benefit element.