Legal Opinion

James D. Kennedy, Jr. And Dorothy H. Kennedy, and Cherokee Warehouses, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided February 4, 1982No. 80-1244, 80-1245PublishedCited by 49 opinions

1Opinion of the Court

WEICK, Circuit Judge.

Petitioners-Appellants have appealed from the decisions of the Tax Court finding them to be liable for deficiencies in their income tax returns for the taxable years 1973 and 1974. The Tax Court’s decisions are reported at 72 T. C. 793 (1979).

In Appeal No. 80-1245, the issue before us is whether the entire amounts paid by appellant Cherokee Warehouses, Inc. to James D. Kennedy, Jr. during its fiscal years ending July 31,1973 and July 31,1974 are deductible as reasonable compensation under I. R. C. section 162(a)(1). The Tax Court held that they are not. We disagree.

In…

2Cases cited28 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  4. Nor-Cal Adjusters, AKA Nor-Cal Insurance Adjusters, Formerly Hobson Adjusters, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
  5. Home Interiors & Gifts, Inc. v. CommissionerUnited States Tax Court · 1980

23 more not listed; retrieve them via the Exa API.

3Cited by49 opinions

  1. King's Court Mobile Home Park, Inc. v. CommissionerUnited States Tax Court · 1992
  2. Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
  3. Luther R. Patton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
  4. Estate of Wallace v. CommissionerUnited States Tax Court · 1990
  5. Centel Communications Co. v. CommissionerUnited States Tax Court · 1989

44 more not listed; retrieve them via the Exa API.

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