Legal Opinion

University Chevrolet Co. v. Commissioner

United States Tax Court

Decided June 29, 1951No. Docket No. 27672Published

Deduction -- Compensation -- Section 23 (a) (1) (A). -- The amount characterized as compensation under a bonus-stock purchasing arrangement adopted by General Motors to obtain and establish dealers is not determinative of reasonable compensation of the same officer after he becomes owner of all of the stock.

1Opinion of the Court

University Chevrolet Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

University Chevrolet Co. v. Commissioner

Docket No. 27672

United States Tax Court

16 T.C. 1452; 1951 U.S. Tax Ct. LEXIS 137;

June 29, 1951, Promulgated

Decision will be entered for the respondent.

Deduction -- Compensation -- Section 23 (a) (1) (A). -- The amount characterized as compensation under a bonus-stock purchasing arrangement adopted by General Motors to obtain and establish dealers is not determinative of reasonable compensation of the same officer after he becomes owner of all of the stock.

Frede…

2Cases cited1 opinion

  1. University Chevrolet Co. v. CommissionerUnited States Tax Court · 1951

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