Rocco v. Commissioner
United States Tax Court
Rocco and Carletta were shareholder-employees of small business corporations. Relying upon sec. 1375(c), I.R.C. 1954, respondent determined that the salaries which they received from such corporations did not reflect the values of the services which they rendered, and reallocated to them portions of the dividends received by the other shareholders. Held: On the facts, the reallocations were improper.
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Rocco and Carletta were shareholder-employees of small business corporations. Relying upon sec. 1375(c), I.R.C. 1954, respondent determined that the salaries which they received from such corporations did not reflect the values of the services which they rendered, and reallocated to them portions of the dividends received by the other shareholders. Held: On the facts, the reallocations were improper. There was no correlation between the amounts determined by respondent to constitute reasonable compensation and the values of the services performed by Rocco and Carletta.
1Opinion of the Court
Charles Rocco and Elizabeth Rocco, Petitioners v. Commissioner of Internal Revenue, Respondent; Ralph Carletta and Mae Carletta, Petitioners v. Commissioner of Internal Revenue, Respondent
Rocco v. Commissioner
Docket Nos. 620-69, 621-69
United States Tax Court
57 T.C. 826; 1972 U.S. Tax Ct. LEXIS 160;
March 20, 1972, Filed
Decisions will be entered for the petitioners.
Rocco and Carletta were shareholder-employees of small business corporations. Relying upon sec. 1375(c), I.R.C. 1954, respondent determined that the salaries which they received from such corporations did not reflect the values of…
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- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Asiatic Petroleum Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Asiatic Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1935
- Dahlem Foundation, Inc. v. CommissionerUnited States Tax Court · 1970
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