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LAKEWOOD MANUFACTURING COMPANY v. C. I. R.

Nos. 71-1223, 71-1224.

453 F.2d 451 (1972)

LAKEWOOD MANUFACTURING COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

January 4, 1972.

Attorney(s) appearing for the Case

William F. Snyder, Cleveland, Ohio, for petitioner-appellant; Marshman, Snyder & Seeley, Cleveland, Ohio, on brief.

Robert S. Watkins, Atty., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee; Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, Elmer J. Kelsey, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief.

Before BROOKS, MILLER and KENT, Circuit Judges.

KENT, Circuit Judge.

This is an appeal by the Taxpayer from an adverse decision by the Tax Court.1 The Taxpayer is a corporation, the stock of which is held by Stephen Peplin and the members of his family. The Taxpayer contests deficiencies in corporate income tax found by the Commissioner resulting from the Commissioner's determination that for the tax years ending May 31, 1962 through May 31, 1967, the salary deducted by the Taxpayer...

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