Adams Tooling, Inc. v. Commissioner
United States Tax Court
Held: A portion of the compensation paid by petitioner to each of two executives (father and son) who, together, were in control of a family-owned corporation, was excessive and unreasonable for their respective services for each of the 2 years in question within the meaning of section 23(a)(1)(A) of the Code of 1939. Amount of excessive and unreasonable compensation determined.
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in the income tax of petitioner as follows:
Year Amount
1952_$47,728.95
1953_ 48, 239.61
95,963.56
The only issue presented is whether or not the compensation paid by petitioner to its two principal officer-shareholders exceeded a reasonable allowance for their respective services, and if so, the amount of such excess.
FINDINGS OF FACT.
Some of the facts have been stipulated and are incorporated herein by this reference. Some of the testimony and exhibits received in the case of Huckins Tool and Die, Inc. (in which case Memorandum of Findings of Fact…
2Cited by11 opinions
- Adams Tooling, Inc., an Indiana Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Albert Van Luit Co. v. CommissionerUnited States Tax Court · 1975
- Ernest, Holdeman & Collet, Inc., a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Owensby & Kritikos, Inc. v. CommissionerUnited States Tax Court · 1985
- Adams Tooling, Inc. v. CommissionerUnited States Tax Court · 1959
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