R. J. Nicoll Co. v. Commissioner
United States Tax Court
Held, that determined amounts paid by petitioner corporation, R. J. Nicoll Co., in 1965, 1966, and 1967, as compensation to petitioner Raymond Nicoll in excess of amounts allowed by respondent are deductible as reasonable compensation for services rendered by Raymond in prior years to corporate petitioner's predecessors, for which services Raymond was undercompensated in those prior years, applying the rule of Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); held, further,…
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Held, that determined amounts paid by petitioner corporation, R. J. Nicoll Co., in 1965, 1966, and 1967, as compensation to petitioner Raymond Nicoll in excess of amounts allowed by respondent are deductible as reasonable compensation for services rendered by Raymond in prior years to corporate petitioner's predecessors, for which services Raymond was undercompensated in those prior years, applying the rule of Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); held, further, that certain amounts paid by petitioner corporation in 1965, 1966, and 1967, as the employees' share of social security…
1Opinion of the Court
R. J. Nicoll Co., Petitioner v. Commissioner of Internal Revenue, Respondent; Raymond Nicoll and Genevieve Nicoll, Petitioners v. Commissioner of Internal Revenue, Respondent
R. J. Nicoll Co. v. Commissioner
Docket Nos. 1759-69, 1760-69
United States Tax Court
59 T.C. 37; 1972 U.S. Tax Ct. LEXIS 47;
October 5, 1972, Filed
Decisions will be entered under Rule 50.
Held, that determined amounts paid by petitioner corporation, R. J. Nicoll Co., in 1965, 1966, and 1967, as compensation to petitioner Raymond Nicoll in excess of amounts allowed by respondent are deductible as reasonable compensation for…
2Cases cited18 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- 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
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