E.J. Harrison and Sons, Inc. - Page 1

          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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