Legal Opinion

Harolds Club v. Commissioner

United States Tax Court

Decided July 29, 1963No. Docket No. 93450Unpublished

Held, a portion of the amounts paid during the years 1952 to 1956, inclusive, by petitioner to its general manager, who was the father of petitioner's controlling shareholders, represented unreasonable compensation.

1Opinion of the Court

Harolds Club v. Commissioner.

Harolds Club v. Commissioner

Docket No. 93450.

United States Tax Court

T.C. Memo 1963-198; 1963 Tax Ct. Memo LEXIS 142; 22 T.C.M. (CCH) 969; T.C.M. (RIA) 63198;

July 29, 1963

Held, a portion of the amounts paid during the years 1952 to 1956, inclusive, by petitioner to its general manager, who was the father of petitioner's controlling shareholders, represented unreasonable compensation.

Valentine Brooks, 1720 Mills Tower, San Francisco, Calif. and John S. Halley, for the petitioner. Leon Yudkin, for the respondent.

FAY

Memorandum Findings of Fact and Opinion

FAY, Judge:…

2Cases cited5 opinions

  1. Miller Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1945
  2. Hoffman Radio Corp. v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1949
  3. Adams Tooling, Inc. v. CommissionerUnited States Tax Court · 1959
  4. Adams Tooling, Inc., an Indiana Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
  5. Connecticut Marine Boiler Works v. Secretary Maritime Com.United States Tax Court · 1951

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