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CHOATE CONSTRUCTION CO. v. COMMISSIONER

Docket No. 20781-95.

74 T.C.M. 1092 (1997)

T.C. Memo. 1997-495

Choate Construction Co. v. Commissioner.

United States Tax Court.

Filed November 4, 1997.

Attorney(s) appearing for the Case

Matthew J. Howard, Marietta, Ga., for the petitioner. Larry D. Anderson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a $212,580 deficiency in petitioner's income tax for 1992.

William Millard Choate (Choate) is petitioner's founder and chief executive officer (CEO). After concessions, the sole issue for decision is whether petitioner may deduct $1,010,000 in compensation for Choate in 1992, as petitioner contends; $265,550, as respondent contends; or some other amount. We hold that petitioner...

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