Pulsar Components Int'l v. Commissioner
United States Tax Court
Held: Compensation paid by P to two of its officers/shareholders is reasonable. Both officers had the appropriate education and employment background for their positions with P, worked long hours for the company and its predecessor, and helped increase its gross sales in a volatile market. The success of the business required great expertise in trading computer chips and microprocessors.
Read the full summary
Held: Compensation paid by P to two of its officers/shareholders is reasonable. Both officers had the appropriate education and employment background for their positions with P, worked long hours for the company and its predecessor, and helped increase its gross sales in a volatile market. The success of the business required great expertise in trading computer chips and microprocessors. These qualities were especially exemplified during the taxable year at issue when P proved profitable even though it faced adverse economic conditions. Moreover, P's retained earnings grew, and P paid regular…
1Opinion of the Court
PULSAR COMPONENTS INTERNATIONAL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pulsar Components Int'l v. Commissioner
Docket No. 15172-92.
United States Tax Court
T.C. Memo 1996-129; 1996 Tax Ct. Memo LEXIS 132; 71 T.C.M. (CCH) 2436;
March 14, 1996, Filed
Decision will be entered for petitioner.
Held: Compensation paid by P to two of its officers/shareholders is reasonable. Both officers had the appropriate education and employment background for their positions with P, worked long hours for the company and its predecessor, and helped increase its gross sales in a volatile…
2Cases cited34 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Parker v. CommissionerUnited States Tax Court · 1986
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
29 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Alpha Medical, Inc., Formerly Known as Alpha Medical Management, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1999