Legal Opinion
Owensby & Kritikos, Inc. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided June 26, 1987No. 86-4073PublishedCited by 59 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
This appeal presents a single question: whether the Tax Court committed clear error in ruling that amounts paid as compensation in 1978 and 1979 by the corporate appellants to the individual appellants were in part unreasonable. The Tax Court held that a portion of the amount paid was in reality a dividend rather than compensation for services rendered. We conclude that the Tax Court’s finding of fact that the compensation paid was in part unreasonable is not clearly erroneous. We therefore affirm.
I
The appellants in this case are two corporate taxpayers, Owensby &…
2Cases cited29 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Welch v. HelveringSupreme Court of the United States · 1933
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
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3Cited by59 opinions
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Exacto Spring Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1999
- James H. Rutter and Marie R. Rutter v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Menard, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 2009
54 more not listed; retrieve them via the Exa API.