JERRE S. WILLIAMS, Circuit Judge:
Appellants challenge the Tax Court's holding that amounts paid as compensation in 1976, 1977, 1978, and 1979 by the J.H. Rutter Rex Manufacturing Company, Inc. to James H. Rutter in part exceeded reasonable compensation for services actually rendered during those taxable years. The Tax Court held that the excessive amounts of compensation constituted payments of dividends and therefore were subject to a higher tax rate. The Tax Court...
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