Dave Fischbein Mfg. Co. v. Commissioner
United States Tax Court
1. Held, that the salaries paid by petitioner-corporations to Dave Fischbein, the chairman of the board of each corporation, during the years in question herein, were reasonable in amount and a proper reflection of the value of the chairman's services rendered to each corporation. 2. Compagnie Fischbein, S.A., is a Belgian subsidiary of Dave Fischbein Co. Under the terms of subpart F of the Code, Compagnie Fischbein, S.A., is a "controlled foreign corporation" and Dave…
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1. Held, that the salaries paid by petitioner-corporations to Dave Fischbein, the chairman of the board of each corporation, during the years in question herein, were reasonable in amount and a proper reflection of the value of the chairman's services rendered to each corporation. 2. Compagnie Fischbein, S.A., is a Belgian subsidiary of Dave Fischbein Co. Under the terms of subpart F of the Code, Compagnie Fischbein, S.A., is a "controlled foreign corporation" and Dave Fischbein Co. is a "United States shareholder" of this controlled foreign corporation. Compagnie Fischbein, S.A., purchases…
1Opinion of the Court
Irwin, Judge:
These cases involve deficiencies in income tax asserted by respondent for petitioners’ taxable years as follows:
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The parties have reached settlement with respect to three of the initial issues involved in docket No. 1455-70. Irrespective of our further disposition of the remaining issues with regard to Dave Fischbein Co., a Rule 50 computation will be required.
The issues remaining for our decision are: (1) Whether salaries paid by both petitioners in 1965, 1966, and 1967 to Dave Fischbein, founder and chief executive officer of petitioners, were reasonable, in whole…
2Cases cited2 opinions
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
3Cited by31 opinions
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Vetco, Inc. v. CommissionerUnited States Tax Court · 1990
- Garnac Grain Co. v. CommissionerUnited States Tax Court · 1990
- Balch v. CommissionerUnited States Tax Court · 1993
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