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HEROLD MARKETING ASSOCIATES, INC. v. COMMISSIONER

Docket No. 1529-97.

77 T.C.M. 1306 (1999)

T.C. Memo. 1999-26

Herold Marketing Associates, Inc. v. Commissioner.

United States Tax Court.

Filed January 29, 1999.

Attorney(s) appearing for the Case

Daniel J. Boivin, Frank R. Berman, and Jeffrey A. Olson, for the petitioner. Jack M. Forsberg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Herold Marketing Associates, Inc., petitioned the Court to redetermine 1992 and 1993 income tax deficiencies of $246,508 and $247,829, respectively. The deficiencies stem from respondent's determination that $700,000 of the $1.2 million in compensation that petitioner paid to its sole shareholder/chief executive officer could not be deducted under section 162(a).

We must decide whether petitioner...

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