T.C. Memo. 1999-26
UNITED STATES TAX COURT
HEROLD MARKETING ASSOCIATES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1529-97. Filed January 29, 1999.
Held: Compensation paid by P to its sole
shareholder/CEO was reasonable.
Daniel J. Boivin, Frank R. Berman, and Jeffrey A. Olson,
for petitioner.
Jack M. Forsberg, for 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
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