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LEONARD PIPELINE CONTRACTORS, LTD. v. C.I.R.

No. 97-70227.

142 F.3d 1133 (1998)

LEONARD PIPELINE CONTRACTORS, LTD. Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 24, 1998.

Attorney(s) appearing for the Case

Timothy Berg, Fennemore Craig, Phoenix, Arizona, for Petitioner-Appellant.

Anthony T. Sheehan, Department of Justice, Tax Division, Washington, DC, for Respondent-Appellee.

Before: WHITE, Justice, and NOONAN and THOMAS, Circuit Judges.

NOONAN, Circuit Judge:

Leonard Pipeline Contractors, Ltd. (the Taxpayer) appeals the judgment of the United States Tax Court limiting the deduction of reasonable compensation to its president, Richard L. Leonard, for the tax year 1987 to $700,000. The case involves the meaning of "reasonable" in the familiar and fundamental statute, 26 U.S.C. § 162, governing the deduction of compensation as an expense of doing business. Holding that the Tax Court has not furnished...

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