Mennuto v. Commissioner
United States Tax Court
1. Respondent determined that purported loans did not constitute bona fide indebtedness of petitioner corporation and that repayments thereof and payments of interest thereon constituted dividends.
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1. Respondent determined that purported loans did not constitute bona fide indebtedness of petitioner corporation and that repayments thereof and payments of interest thereon constituted dividends. Held, the purported loans were bona fide indebtedness with the result that the repayments thereof were nontaxable and the interest was deductible by petitioner corporation. 2. Respondent determined that a portion of the salaries and bonuses paid to employee-stockholders by petitioner corporation was unreasonable and constituted nondeductible dividends. Held, amount of reasonable compensation…
1Opinion of the Court
Anthony Mennuto and Stacia Mennuto, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Mennuto v. Commissioner
Docket Nos. 2908-70, 2909-70, 2910-70, 2924-70, 3000-70, 3001-70
United States Tax Court
56 T.C. 910; 1971 U.S. Tax Ct. LEXIS 90;
August 2, 1971, Filed
Decisions will be entered under Rule 50.
1. Respondent determined that purported loans did not constitute bona fide indebtedness of petitioner corporation and that repayments thereof and payments of interest thereon constituted dividends. Held, the purported loans were bona fide indebtedness with the result that the…
2Cases cited28 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- 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
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
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