Pahl v. Commissioner
United States Tax Court
On Dec. 14, 1970, petitioner John G. Pahl executed a contract, stated to be effective Jan. 1, 1969, whereby he agreed to restore to a corporation he controlled any amounts received as compensation, expense reimbursements, rentals, interest, etc., which were subsequently disallowed as income tax deductions.
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On Dec. 14, 1970, petitioner John G. Pahl executed a contract, stated to be effective Jan. 1, 1969, whereby he agreed to restore to a corporation he controlled any amounts received as compensation, expense reimbursements, rentals, interest, etc., which were subsequently disallowed as income tax deductions. The Internal Revenue Service later disallowed a portion of the deductions claimed by the corporation as compensation for petitioner's services during 1969 and 1970 and petitioners in 1972 restored the disallowed amounts. Held, petitioners are not entitled under either sec. 1341(a) or…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined a deficiency of $35,191 in petitioners’ Federal income tax for 1972. The issue to be decided is whether petitioners John G. Pahl and Beverley B. Pahl are entitled to a deduction in 1972 for the repayment of that portion of the compensation which petitioner John G. Pahl received in 1969 and 1970 from a corporation he controlled and for which the corporation was not allowed deductions in those years under section 162(a).1
All the facts are stipulated.
At the time the petition in this proceeding was filed, petitioners were legal residents of…
2Cases cited16 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- United States v. LewisSupreme Court of the United States · 1951
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Hope v. CommissionerUnited States Tax Court · 1971
11 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Dominion Resources, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 2000
- William E. Bailey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- Anderson v. CommissionerUnited States Tax Court · 1976
- Uhlenbrock v. CommissionerUnited States Tax Court · 1977
- Cinergy Corp. v. United StatesUnited States Court of Federal Claims · 2003
18 more not listed; retrieve them via the Exa API.