Steffen v. Commissioner
United States Tax Court
Dr. Steffen's employee and shareholder relationship with the Corporation was terminated pursuant to an agreement under which he received $ 40,000 cash and other property. The value of the Corporation's accounts receivable was considered in arriving at the amount to be paid Dr. Steffen.
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Dr. Steffen's employee and shareholder relationship with the Corporation was terminated pursuant to an agreement under which he received $ 40,000 cash and other property. The value of the Corporation's accounts receivable was considered in arriving at the amount to be paid Dr. Steffen. Held, the portion of the $ 40,000 paid to Dr. Steffen which was attributable to the Corporation's accounts receivable did not constitute compensation to Dr. Steffen for which the Corporation is entitled to a salary expense deduction.
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in the Federal income taxes of petitioners as follows:
Docket No. Year Deficiency
8988-76 .1973 $20,329.13
9514^76 .1974 18,356.02
Due to concessions, the only issue remaining for decision in these consolidated cases is whether an amount paid to Dr. Ted N. Steffen by Drs. Jones, Richmond, Peisel, P.S.C. (hereinafter Corporation) was entirely for the redemption of his stock in the Corporation or whether it constituted in part compensation for services rendered.
FINDINGS OF FACT
Some of the facts have been stipulated and they are so found. Petitioners…
2Cases cited9 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Klein v. Board of Tax Supervisors of Jefferson Cty.Supreme Court of the United States · 1930
- Commissioner v. GordonSupreme Court of the United States · 1968
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Anderson v. CommissionerUnited States Tax Court · 1976
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3Cited by11 opinions
- Wenzel v. Hopper & Galliher, P.C.Indiana Court of Appeals · 2002
- Estate of Robert E. Cartwright, Deceased, Dorothy G. Cartwright v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- UNITED STATES TAX COURT FRONTIER CHEVROLET CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Russo v. Comm'rUnited States Tax Court · 1979
- Chekow v. CommissionerUnited States Tax Court · 1978
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