Home Interiors & Gifts, Inc. v. Commissioner
United States Tax Court
From 1971 through 1975, X, Y, and Z received very substantial compensation from C consisting of salaries, bonuses, and commissions based on a percentage of the sales of C. X and Y, who were related, owned, with their families, slightly more than 50 percent of the stock of C; Z, who was not related to X and Y, owned a negligible amount of stock.
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From 1971 through 1975, X, Y, and Z received very substantial compensation from C consisting of salaries, bonuses, and commissions based on a percentage of the sales of C. X and Y, who were related, owned, with their families, slightly more than 50 percent of the stock of C; Z, who was not related to X and Y, owned a negligible amount of stock. From 1971 thorugh 1975, C enjoyed extraordinary success in sales and profits; it paid high dividends, and the value of its stock increased sharply. Held, under all the circumstances, the compensation of X, Y, and Z during such years was reasonable…
1Opinion of the Court
Home Interiors & Gifts, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Home Interiors & Gifts, Inc. v. Commissioner
Docket Nos. 9007-77, 9573-78, 9574-78, 9697-78
United States Tax Court
73 T.C. 1142; 1980 U.S. Tax Ct. LEXIS 163;
March 24, 1980, Filed
Decisions will be entered under Rule 155.
From 1971 through 1975, X, Y, and Z received very substantial compensation from C consisting of salaries, bonuses, and commissions based on a percentage of the sales of C. X and Y, who were related, owned, with their families, slightly more than 50 percent of the stock of C; Z, who…
2Cases cited21 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Pacific Grains, Inc., an Oregon Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Home Interiors & Gifts, Inc. v. CommissionerUnited States Tax Court · 1980
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