T.C. Memo. 2003-15
UNITED STATES TAX COURT
DEVINE BROTHERS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8135-01. Filed January 16, 2003.
Lowell F. Raeder and David R. White, Jr., for petitioner.
Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $25,086
in petitioner’s Federal income tax for the fiscal year ended
February 28, 1995. After concessions, the issue for decision is
whether deductions claimed by petitioner for salary and bonuses
paid to one of its officers, who was also a shareholder, exceeded
reasonable compensation. Unless otherwise indicated, all section
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