Menard, Inc. - Page 1
130 T.C. No. 4
UNITED STATES TAX COURT
MENARD, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
JOHN R. MENARD, Petitioner v.
COMMISSIONER OF THE INTERNAL REVENUE, Respondent*
Docket Nos. 673-02, 674-02. Filed February 19, 2008.
MI is an accrual basis taxpayer with a fiscal year
ending Jan. 31. S is a cash basis taxpayer who was the
president, CEO, and 89-percent shareholder of MI during
MI’s TYE 1998.
In an earlier opinion, the Court concluded that a
portion of the compensation that MI paid to S during
TYE 1998 was unreasonable and represented a disguised
dividend, and consequently MI was liable for an income
tax deficiency to the extent S’s compensation was not
deductible as an ordinary and necessary business
*This Opinion supplements our previously filed opinions in
Menard, Inc. v. Commissioner, T.C. Memo. 2004-207, and Menard,
Inc. v. Commissioner, T.C. Memo. 2005-3.
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Last modified: March 27, 2008