Legal Opinion

Herold Mktng. Assoc. v. Commissioner

United States Tax Court

Decided January 29, 1999No. 1529-97Unpublished

HELD: Compensation paid by P to its sole shareholder/CEO was reasonable.

1Opinion of the Court

HEROLD MARKETING ASSOCIATES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Herold Mktng. Assoc. v. Commissioner

No. 1529-97

United States Tax Court

T.C. Memo 1999-26; 1999 Tax Ct. Memo LEXIS 22; 77 T.C.M. (CCH) 1306; T.C.M. (RIA) 99026;

January 29, 1999, Filed

Decision will be entered for petitioner.

HELD: Compensation paid by P to its sole shareholder/CEO was reasonable.

Daniel J. Boivin, Frank R. Berman, and Jeffrey A. Olson, for petitioner.

Jack M. Forsberg, for respondent.

LARO, JUDGE.

LARO

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, JUDGE: Herold Marketing Associates, Inc.,…

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
  4. Parker v. CommissionerUnited States Tax Court · 1986
  5. Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1976

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