opinion: PER CURIAM.
  In this appeal the taxpayer (Savko Brothers Company) seeks to reverse a tax deficiency judgment of $4,096.79. The Commissioner had previously found (and had contended before the Tax Court for) a deficiency of $36,496.51. The dispute turns upon whether or not salaries. and bonuses paid to the corporation’s two principal officers and stockholders were or were not “reasonable” within the meaning of Internal Revenue Code of 1954, § 162(a) (l).
  Two brothers, Nick and Charley Savko, were recipients of the salaries and bonuses and paid personal income taxes thereon. They had organized the corporation late in 1955 to engage in the building, construction and excavating business in which both had considerable prior experience. It is undisputed that through their joint efforts in estimating jobs, in getting business, in laying out work and supervising it, they were personally responsible for the considerable success of the company.
  The financial picture of the taxpayer company is shown in these figures:
  Year Ending June 30 Gross Receipts Net Income (Loss) Total Compensation to Savkos
  1957 $461,666.10 $(11,273.85) $62,500
  1958 555,672.88 26,205.24 49.000
  1959 775,916.01 38,683.27 52.000
  The Commissioner’s and the Tax compensation was as follows: Court’s treatment of the Savkos’ total
  Commissioner Tax Court
  Taxable Year Ended June 30 Compensation Allowed Tax Deficiency Compensation Allowed Tax Deficiency
  1957 $26,000.00 $ 6,873.11 $49,000.00 $ -0-
  1958 26,000.00 16,103.40 49.000. 00 4,096.79
  1959 26,000.00 13,520.00 52.000. 00 -0-
  The Tax Court on this record held amounts paid each of the Savko brothers in 1957 “was unreasonable as compensation for services actually rendered * * * to the extent of $6,750 each.” It thus appears that the Tax Court allowed $24,500 as “reasonable” compensation to each officer for the first year of operation of the company at a time when the company showed a loss. This was the same compensation which the company paid to each brother in the following year — the first year when the company showed a profit.
  Under this record we cannot say that the Tax Court’s determination was “clearly erroneous.” Rule 52(a) Fed. R.Civ.P.; Commissioner of Internal Revenue v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218 (1960) v. United States v. United States Gypsum Co., 333 U.S. 364, 68 S.Ct. 525, 92 L.Ed. 746 (1948).
  Affirmed.
  . § 162. Trade or business expenses.
  “(a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including — •
  “(1) a reasonable allowance for salaries or other compensation for personal services actually rendered; * * * ” 26 U.S.C.1958 ed., Sec. 162 (a) (1).
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "construction". Your task is to determine what subcategory of business best describes this litigant.
choices: residential commercial or industrial other unclear