Clymer v. Commissioner
United States Tax Court
Clymer was the sole stockholder and chief executive officer of Denison, a Coors beer distributor in northern Texas. In 1970 Clymer entered into an oral agreement with Denison under which he received a salary of $27,000 a year plus 20 percent of the net profits before taxes of Denison. Held: Amounts paid to Clymer in 1974, 1975 and 1976 under the contingent compensation agreement exceeded reasonable compensation for his services. Reasonable compensation determined.
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Clymer was the sole stockholder and chief executive officer of Denison, a Coors beer distributor in northern Texas. In 1970 Clymer entered into an oral agreement with Denison under which he received a salary of $27,000 a year plus 20 percent of the net profits before taxes of Denison. Held: Amounts paid to Clymer in 1974, 1975 and 1976 under the contingent compensation agreement exceeded reasonable compensation for his services. Reasonable compensation determined. Held,Further:Denison may not deduct expenses of operating airplanes owned by it primarily for business purposes attributable to…
1Opinion of the Court
RAY CLYMER, JR. and DENISON POULTRY & EGG CO., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Clymer v. Commissioner
Docket Nos. 9138-79, 9139-79.
United States Tax Court
T.C. Memo 1984-203; 1984 Tax Ct. Memo LEXIS 476; 47 T.C.M. (CCH) 1576; T.C.M. (RIA) 84203;
April 23, 1984.
Clymer was the sole stockholder and chief executive officer of Denison, a Coors beer distributor in northern Texas. In 1970 Clymer entered into an oral agreement with Denison under which he received a salary of $27,000 a year plus 20 percent of the net profits before taxes of Denison.
Held: Amounts paid to Clymer…
2Cases cited42 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ashe v. SwensonSupreme Court of the United States · 1970
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Arizona v. CaliforniaSupreme Court of the United States · 1983
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