Mon E. Bags, Chief Executive Officer of Earns A Lot Enterprises, received total compensation of $2,500,000.00 in 2017. The compensation included a base salary of $750,000, a commission income of $1,250,000, and a performance bonus of $500,000. Mr. Bags compensation placed him in the top 25% of all the chief executives in the industry.

Earns A Lot is located in State X. While the national economy has experienced an economic slowdown, State X has a strong and vibrant economy. Mr. Bags has been the chief executive officer for five years.

Earns A Lot, which has long had a reputation for paying very competitive salaries, recruited Mr. Bags from its chief rival, Wanna Be Industries. When Mr. Bags became the chief executive of Wanna Be, the company was on the verge of liquidation. Within five years, Mr. Bags took Wanna Be from the steps of oblivion to the top of the industry.

While Earns A Lot has a solid reputation of consistent top tier performance, it has long believed there was room for substantial growth and so hired Mr. Bags. Indeed, under Mr. Bags leadership, Earns A Lot has seen gross revenues grow by over 20% per year. Nonetheless, Earns A Lot is concerned about whether the company will be able to deduct Mr. Bags 2017 compensation.

Will Earns A Lot be able to deduct Mr. Bags 2017 compensation? 

Please write a legal memo answering this question, citing the appropriate authority USA cases only. 

An IRAC-style essay is appropriate for this assignment.