Legal Opinion

Hughes v. Commissioner

United States Tax Court

Decided September 2, 1964No. Docket Nos. 2918-62, 2919-62Published

Petitioners, on a calendar year basis, were the principal stockholders and the salaried executive officers of a closely held corporation with a fiscal year ended June 30. The corporation maintained an account for each petitioner which it reflected as a debit or a credit on its balance sheets at all times.

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Petitioners, on a calendar year basis, were the principal stockholders and the salaried executive officers of a closely held corporation with a fiscal year ended June 30. The corporation maintained an account for each petitioner which it reflected as a debit or a credit on its balance sheets at all times. The only corporate action respecting petitioners' salaries for the calendar year 1959 was a resolution authorizing $ 400 per month to each "with the understanding that a bonus will be paid as additional compensation * * * at the end of the year if the company earns a satisfactory profit."…

1Opinion of the Court

R. E. Hughes, Jr., and Martha Hughes, Petitioners, v. Commissioner of Internal Revenue, Respondent; Calvin B. Morgan and Rita H. Morgan, Petitioners, v. Commissioner of Internal Revenue, Respondent

Hughes v. Commissioner

Docket Nos. 2918-62, 2919-62

United States Tax Court

42 T.C. 1005; 1964 U.S. Tax Ct. LEXIS 48;

September 2, 1964, Filed

Decision will be entered under Rule 50.

Petitioners, on a calendar year basis, were the principal stockholders and the salaried executive officers of a closely held corporation with a fiscal year ended June 30. The corporation maintained an account for each…

2Cases cited28 opinions

  1. Burnet v. ClarkSupreme Court of the United States · 1932
  2. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
  3. Dalton v. BowersSupreme Court of the United States · 1932
  4. Klein v. Board of Tax Supervisors of Jefferson Cty.Supreme Court of the United States · 1930
  5. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948

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