NATIONAL UNDERWRITERS, INC. v. COMMISSIONER

Docket No. 4554-71.

33 T.C.M. 49 (1974)

T.C. Memo. 1974-14

National Underwriters, Inc. v. Commissioner.

United States Tax Court.

Filed January 23, 1974.


Attorney(s) appearing for the Case

Harold N. Roney, Box 590, McMinnville, Tenn., for the petitioner. John B. Harper, for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income taxes for its taxable years ended December 31, 1966 and December 31, 1967 in the amounts of $12,767.49 and $10,914.07, respectively. The issue for decision is whether payments made to petitioner's four officer-shareholders in 1966 and 1967 in excess of $16,000 and $16,032.90, respectively, were reasonable compensation for personal services actually...

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