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ALPHA MEDICAL, INC. v. C.I.R.

No. 98-1406.

172 F.3d 942 (1999)

ALPHA MEDICAL, INC., formerly known as Alpha Medical Management, Inc., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 19, 1999.

Attorney(s) appearing for the Case

John P. Konvalinka (argued and briefed), Thomas E. Smith (briefed), Antonio L. Matthews (briefed), Grant, Konvalinka & Harrison, Chattanooga, TN, for Petitioner-Appellant.

Richard Farber (briefed), Patricia Bowman (argued and briefed), U.S. Department of Justice, Appellate Section, Tax Division, Washington, DC, for Respondent-Appellee.

Before: MERRITT, KENNEDY, and JONES, Circuit Judges.

MERRITT, Circuit Judge.

During 1990, Taxpayer Alpha Medical Management, Inc., a medical management corporation in Tennessee, paid Mr. William Rogers, its president, director, and sole shareholder, compensation totaling $4,439,180 and claimed a deduction for that amount on its tax return for that year. Upon audit of that return, the Internal Revenue Service determined that the compensation paid to Rogers, to the extent it exceeded $400,000, was unreasonable and, therefore...

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