T.C. Memo. 2003-200
UNITED STATES TAX COURT
BREWER QUALITY HOMES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8222-99. Filed July 10, 2003.
R disallowed deductions for portions of amounts P paid
to a shareholder-officer.
Held: (1) Maximum amounts of reasonable compensation
(less than amounts P deducted, but greater than amounts R
determined) are redetermined.
(2) The amounts so redetermined were paid as
compensation for personal services actually rendered and are
deductible. The amounts P paid in excess of the amounts so
redetermined are not deductible. Sec. 162(a)(1), I.R.C.
1986.
R. Cody Mayo, Jr., for petitioner.
Mary Beth Calkins and Joseph Ineich, for respondent.
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