Legal Opinion

Boyle Fuel Co. v. Commissioner

United States Tax Court

Decided November 4, 1969No. Docket Nos. 2608-66, 2609-66PublishedCited by 27 opinions

Held: On the facts presented, the amounts paid by each of the petitioners as compensation for the services of their respective officers were unreasonable and excessive. Reasonable compensation determined.

1Opinion of the Court

BRUCE, Judge:

Respondent determined deficiencies in corporation income tax of Boyle Fuel Co. for fiscal years ended April 30, and of Spokane Heating Co. for fiscal years ended January 31, as follows:

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The sole issue remaining for decision is whether respondent erred in determining that the deductions claimed on the petitioners’ returns for salaries of officers were excessive, and, if so, in what amounts.

FINDINGS OF FACTS

The stipulation of facts and exhibits attached thereto are incorporated by reference.

Boyle Fuel Co. is a corporation organized under the laws of the State of…

2Cases cited5 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  3. Leach v. CommissionerUnited States Tax Court · 1953
  4. Heil Beauty Supplies, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
  5. Geiger & Peters, Inc. v. CommissionerUnited States Tax Court · 1957

3Cited by27 opinions

  1. Kennedy v. CommissionerUnited States Tax Court · 1979
  2. R. J. Nicoll Co. v. CommissionerUnited States Tax Court · 1972
  3. Dahlem Foundation, Inc. v. CommissionerUnited States Tax Court · 1970
  4. S. & B. Realty Co. v. CommissionerUnited States Tax Court · 1970
  5. Hudlow v. CommissionerUnited States Tax Court · 1971

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