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KAW DEHYDRATING CO. INC. v. COMMISSIONER

Docket No. 10334-77.

74 T.C. 370 (1980)

KAW DEHYDRATING COMPANY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 20, 1980.

Attorney(s) appearing for the Case

Murray F. Hardesty, for the petitioner.

James E. Cannon, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in petitioner's Federal income tax for the calendar year 1973 in the amount of $29,693.62. The sole remaining issue is whether the amount of $61,739.06 claimed deductible as accrued bonuses for two of petitioner's controlling cash basis shareholders was constructively received by them within petitioner's taxable year and 2½ months thereafter within the intendment of section 267.

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