T.C. Memo. 2005-114
UNITED STATES TAX COURT
MILLER & SONS DRYWALL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1241-03. Filed May 19, 2005.
Rodger G. Mohagen, for petitioner.
David W. Sorensen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: On January 6, 2003, respondent issued a
notice of deficiency determining Federal income tax deficiencies
for petitioner’s tax years ended June 30, 1998, 1999, and 2000,
of $82,686, $83,016, and $103,855, respectively. Among other
things, respondent partially disallowed petitioner’s deductions
for compensation paid to its shareholder-employees of $204,577 in
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