Legal Opinion
Elliotts, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 26, 1983No. 81-7173PublishedCited by 91 opinions
1Opinion of the Court
HUG, Circuit Judge:
Elliotts, Inc. (“Taxpayer”), challenges the Tax Court’s determination of deficiencies in its 1975 and 1976 tax returns. It argues that the Tax Court erred in finding that part of the compensation paid Taxpayer’s chief executive and sole shareholder during those years constituted a dividend distribution and thus was not deductible under section 162(a)(1) of the Internal Revenue Code. We reverse.
I
BACKGROUND
Taxpayer is an Idaho corporation that sells equipment manufactured by John Deere Co. and services equipment made by Deere and several other manufacturers. Its principal…
2Cases cited19 opinions
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- United States v. ByrumSupreme Court of the United States · 1972
- Nor-Cal Adjusters, AKA Nor-Cal Insurance Adjusters, Formerly Hobson Adjusters, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Pacific Grains, Inc., an Oregon Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Charles Schneider & Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1974
14 more not listed; retrieve them via the Exa API.
3Cited by91 opinions
- In Re: Nell Carter, Debtor. Nell Carter v. Peter C. Anderson, Chapter 7trustee,appelleeCourt of Appeals for the Ninth Circuit · 1999
- David E. Watson, Pc v. United StatesCourt of Appeals for the Eighth Circuit · 2012
- Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
- Luther R. Patton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
86 more not listed; retrieve them via the Exa API.