Graphic Business Systems, Inc. v. Commissioner
United States Tax Court
(1) Graphic and its three major shareholders were sued for $ 1,050,000, an accounting of profits, and an injunction. The four defendants counterclaimed for an aggregate of $ 1,340,283.42. The suit was settled by Graphic paying $ 5,000 to the plaintiff; Graphic also paid the defendants' attorney's fee of $ 650. Held: Graphic may deduct its payments in full. (2) Graphic owned 70 percent of the outstanding stock of VRE.
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(1) Graphic and its three major shareholders were sued for $ 1,050,000, an accounting of profits, and an injunction. The four defendants counterclaimed for an aggregate of $ 1,340,283.42. The suit was settled by Graphic paying $ 5,000 to the plaintiff; Graphic also paid the defendants' attorney's fee of $ 650. Held: Graphic may deduct its payments in full. (2) Graphic owned 70 percent of the outstanding stock of VRE. The remaining 30 percent was owned by R, who was unrelated to the shareholders of Graphic. Held: the 80-percent requirement of section 1563(a)(2)(A), I.R.C. 1954, is not…
1Opinion of the Court
GRAPHIC BUSINESS SYSTEMS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; VRE, INC., VISIBLE RECORD EQUIPMENT CO., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Graphic Business Systems, Inc. v. Commissioner
Docket Nos. 5125-78 and 5126-78.
United States Tax Court
T.C. Memo 1982-167; 1982 Tax Ct. Memo LEXIS 583; 43 T.C.M. (CCH) 957; T.C.M. (RIA) 82167;
March 30, 1982.(1) Graphic and its three major shareholders were sued for $ 1,050,000, an accounting of profits, and an injunction. The four defendants counterclaimed for an aggregate of $ 1,340,283.42. The suit was…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. GilmoreSupreme Court of the United States · 1963
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Commissioner v. TellierSupreme Court of the United States · 1966
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3Cited by1 opinion
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