GARRISON v. COMMISSIONER

Docket No. 5405-67.

52 T.C. 281 (1969)

JOSEPH GARRISON AND IDA GARRISON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 15, 1969.


Attorney(s) appearing for the Case

Nathan D. Rollins, for the petitioners.

Harvey N. Shapiro, for the respondent.


TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1964 in the amount of $4,474.82. The sole issue for our determination is whether $15,000 of a bonus paid by Garrison Produce Co. to petitioner Joseph M. Garrison, which was admittedly excessive compensation, is taxable as compensation or as a liquidating distribution. Certain other adjustments on which the parties have reached...

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