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METRO LEASING v. COM'R, INTERNAL REVENUE

No. 02-73933.

376 F.3d 1015 (2004)

METRO LEASING AND DEVELOPMENT CORPORATION; East Bay Chevrolet Company, A Corporation, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed July 23, 2004.

Attorney(s) appearing for the Case

Burgess J.W. Raby, Raby Law Office, Tempe, AZ, for the petitioners-appellants.

Andrea R. Tebbets, Department of Justice, Tax Division, Washington, DC, for the respondent-appellee.

Before SCHROEDER, Chief Judge, TALLMAN and CALLAHAN, Circuit Judges.

TALLMAN, Circuit Judge.

This appeal involves the 1995 federal tax return filed by the Metro Leasing and Development Corporation and the East Bay Chevrolet Company (collectively "Metro Leasing"), two small, closely-held California corporations. We must decide whether the United States Tax Court properly determined the amount of a corporate officer's salary that Metro Leasing may deduct as a reasonable business expense under 26 U.S.C. § 162(a)(1). We affirm because...

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