T.C. Memo. 2003-239
UNITED STATES TAX COURT
E.J. HARRISON AND SONS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5316-01. Filed August 13, 2003.
P was engaged in the waste pickup and disposal
business, servicing several California communities.
During the years in question, H was one of four
officers of P, the other three being her sons, who were
responsible for all of the key management functions on
P’s behalf. R disallowed a portion of P’s deduction
for compensation paid to H on the ground that it was
unreasonable and excessive.
Held: Reasonable compensation for H determined.
See sec. 162(a), I.R.C.
Philip Garrett Panitz, for petitioner.
Ryan D. Schaap (specially recognized), for petitioner.
Jonathan H. Sloat and Linette B. Angelastro, for respondent.
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