Yelencsics v. Commissioner
United States Tax Court
Petitioners purchased all the issued and outstanding stock of X corporation from its sole shareholder for cash and promissory notes. Petitioners and X corporation cosigned the notes. The purchase agreement included an employment provision under which X corporation would pay seller $ 70,000 over 4 years for his remaining available to provide consulting services to X corporation.
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Petitioners purchased all the issued and outstanding stock of X corporation from its sole shareholder for cash and promissory notes. Petitioners and X corporation cosigned the notes. The purchase agreement included an employment provision under which X corporation would pay seller $ 70,000 over 4 years for his remaining available to provide consulting services to X corporation. Held, payments by X corporation to seller under the consulting agreement are deductible under sec. 162, I.R.C. 1954. Held, further, payments by X corporation in partial satisfaction of the promissory notes issued…
1Opinion of the Court
Wiles, Judge:
Respondent determined the following deficiencies and additions to tax in petitioners’ Federal income taxes:
Docket Taxable Sec. 6653(a)2 Petitioner No. year Deficiency addition to tax
Anthony Yelencsics and Norma Yelencsics 2078-77 1967 $9,365.77
1968 3,146.59
1969 4,920.63
Steve Yelencsics and Rose Yelencsics 2079-77 1967 7,820.08
1968 4,790.31
1969 6,193.46
Joseph Yelencsics and Margaret Yelencsics 2080-77 1967 7,049.71
1968 3,664.59
1969 6,291.27
John Y. Rawson and Mabel Rawson 2224-77 1967 36,296.97 $1,814.85
1968 11,270.10 563.51
1969 17,988.24 899.41
Rawson Cadillac, Inc. 2223-77…
2Cases cited40 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Enoch v. CommissionerUnited States Tax Court · 1972
- Marcello v. CommissionerUnited States Tax Court · 1964
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3Cited by73 opinions
- Derr v. CommissionerUnited States Tax Court · 1981
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- Norman v. CommissionerUnited States Tax Court · 1987
- Schulman v. CommissionerUnited States Tax Court · 1989
- Huff v. CommissionerUnited States Tax Court · 1983
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