Mennuto v. Commissioner
United States Tax Court
1. Respondent determined that purported loans did not constitute bona fide indebtedness of petitioner corporation and that repayments thereof and payments of interest thereon constituted dividends.
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1. Respondent determined that purported loans did not constitute bona fide indebtedness of petitioner corporation and that repayments thereof and payments of interest thereon constituted dividends. Held, the purported loans were bona fide indebtedness with the result that the repayments thereof were nontaxable and the interest was deductible by petitioner corporation. 2. Respondent determined that a portion of the salaries and bonuses paid to employee-stockholders by petitioner corporation was unreasonable and constituted nondeductible dividends. Held, amount of reasonable compensation…
1Opinion of the Court
Tannenwald, Judge:
Bespondent determined the following income tax deficiencies in these consolidated cases:
Petitioners Deficiency determined Docket -• No. 1966 1967
Anthony Mennuto and Stacia Mennuto.-Philip Russo and Concetta Russo... Martin J. Herman and Roslyn Herman.. Charles W. Muscarelle and Antoinette Muscarelle.., Irving Schornstein and Iris Schornstein. Electro-Pinish Corp. 2908-70 2909-70 2910-70 2924-70 . 3000-70 $2,693.20 7.866.89 . 3.184.90 ’"2’610 24~ $2,836.29 "*2^78082 7,636.00 2,483.39 3001-70 . 40,691.89
The issues remaining for decision are:(1) Whether certain advances made to…
2Cases cited27 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
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3Cited by63 opinions
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- Dielectric Materials Co. v. CommissionerUnited States Tax Court · 1972
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
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