Jerome Castree Interiors, Inc. v. Commissioner
United States Tax Court
During each of the taxable years at issue, the controlling shareholders of the petitioner met and decided on the amount of the bonus to be received by each of them for the year, but such bonuses were not paid within the taxable year or within 2 1/2 months after the close of the taxable year. Nor was the amount of each bonus entered on the books and records of the corporation, and the controlling shareholders did not report the bonuses until the year of payment.
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During each of the taxable years at issue, the controlling shareholders of the petitioner met and decided on the amount of the bonus to be received by each of them for the year, but such bonuses were not paid within the taxable year or within 2 1/2 months after the close of the taxable year. Nor was the amount of each bonus entered on the books and records of the corporation, and the controlling shareholders did not report the bonuses until the year of payment. Held, under the circumstances, the amount of each bonus was not constructively received during the taxable year or within 2 1/2…
1Opinion of the Court
Jerome Castree Interiors, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Jerome Castree Interiors, Inc. v. Commissioner
Docket No. 5863-73
United States Tax Court
64 T.C. 564; 1975 U.S. Tax Ct. LEXIS 115;
July 14, 1975, Filed
Decision will be entered for the respondent.
During each of the taxable years at issue, the controlling shareholders of the petitioner met and decided on the amount of the bonus to be received by each of them for the year, but such bonuses were not paid within the taxable year or within 2 1/2 months after the close of the taxable year. Nor was the amount of…
2Cases cited20 opinions
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Fountain v. CommissionerUnited States Tax Court · 1973
- Geiger & Peters, Inc. v. CommissionerUnited States Tax Court · 1957
- Platt Trailer Co. v. CommissionerUnited States Tax Court · 1955
- Gullett v. CommissionerUnited States Board of Tax Appeals · 1935
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