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AMERICAN INTERNATIONAL COAL CO., INC. v. COMMISSIONER

Docket No. 14574-79.

43 T.C.M. 1097 (1982)

T.C. Memo. 1982-204

American International Coal Co., Inc. v. Commissioner.

United States Tax Court.

Filed April 15, 1982.

Attorney(s) appearing for the Case

Roy J. Roscoe, 400 Manordale Road, Pittsburgh, Pa., for the petitioner. Edward F. Peduzzi, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $21,975.87 in petitioner's Federal income tax for 1975. The sole issue1 for decision is whether petitioner, a corporation, paid Stephen C. Levitt, an employee and shareholder, $54,800 as deductible compensation for services or as a nondeductible distribution in redemption of his stock.

Findings of Fact

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