ELLIOTTS, INC. v. COMMISSIONER

Docket No. 10576-78.

48 T.C.M. 1245 (1984)

T.C. Memo. 1984-516

Elliotts, Inc. v. Commissioner.

United States Tax Court.

Filed September 27, 1984.


Attorney(s) appearing for the Case

William H. Adams, 200 South Main St., Salt Lake City, Utah. Glen E. Clark and William K. Smith, for the petitioner. Dan A. Lisonbee and Julie E. Tamuleviz, for the respondent.


Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for its fiscal years ending February 28, 1975, and February 28, 1976, in the amounts of $58,159.91 and $62,507.38, respectively. The issue for decision is the amount which petitioner is entitled to deduct in each of its fiscal years 1975 and 1976 as reasonable compensation to its sole stockholder, chief executive officer...

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