T.C. Memo. 2005-243
UNITED STATES TAX COURT
CHICKIE’S AND PETE’S, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6354-04. Filed October 17, 2005.
Harry C. Citrino, Jr., for petitioner.
Gerald A. Thorpe, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined a deficiency of
$304,328 in petitioner’s Federal income tax for the taxable year
ended June 30, 2000 (year at issue).
We must decide whether petitioner is entitled to deduct for
the year at issue the portion of a $902,476 payment that it made
to its sole stockholder and officer in excess of the amount of
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