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YOUNG v. C. I. R.

No. 80-7003.

650 F.2d 1083 (1981)

Robert A. YOUNG and Gertrude R. Young, and R. & G. Young Vineyards, Inc., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Decided July 13, 1981.

Attorney(s) appearing for the Case

Edwin C. Anderson, Jr., Spridgen, Barrett, Achor, Luckhardt, Anderson & James, Santa Rosa, Cal., for petitioners.

Kristina E. Harrigan, Washington, D. C., for respondent.

Before TANG and CANBY, Circuit Judges, and WILLIAMS, District Judge.

DAVID W. WILLIAMS, District Judge:

This is an appeal from a Tax Court decision finding deficiencies in the corporate income taxes of R. and G. Young Vineyards for the fiscal years 1973 and 1974. At issue is whether the salary and bonus paid by the corporation to its president, Robert Young, constituted reasonable compensation deductible as a business expense under Section 162(a)(1) of the Internal Revenue Code. 26 U.S.C. § 162(a)(1).

Robert Young has...

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