Legal Opinion

Medina v. Commissioner

United States Tax Court

Decided May 9, 1983No. Docket Nos. 4083-77, 4084-77, 4085-77, 4086-77, 4087-77, 10591-78, 3208-79, 3209-79, 3210-79, 3211-79Unpublished

Held, based on all the facts presented, the compensation paid by the petitioner corporations to their president/majority stockholder was reasonable. Held further, the payments made by the petitioner corporation to relatives of its majority stockholder were not purely for services rendered and are adjusted accordingly. Held further, the petitioner corporations' profit sharing plan was qualified under sec. 401, I.R.C. 1954, during the years in question.

1Opinion of the Court

GERALDINE C. MEDINA, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Medina v. Commissioner

Docket Nos. 4083-77, 4084-77, 4085-77, 4086-77, 4087-77, 10591-78, 3208-79, 3209-79, 3210-79, 3211-79.

United States Tax Court

T.C. Memo 1983-253; 1983 Tax Ct. Memo LEXIS 528; 46 T.C.M. (CCH) 76; T.C.M. (RIA) 83253;

May 9, 1983.

Held, based on all the facts presented, the compensation paid by the petitioner corporations to their president/majority stockholder was reasonable. Held further, the payments made by the petitioner corporation to relatives of its majority stockholder were not…

2Cases cited10 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
  3. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  4. Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
  5. Home Interiors & Gifts, Inc. v. CommissionerUnited States Tax Court · 1980

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