Kennedy v. Commissioner
United States Tax Court
Cherokee, a closely held warehousing corporation, had paid its general manager, James, under an incentive compensation arrangement since its incorporation in 1951. James, a trust for his sister's benefit, and his father held all of Cherokee's stock in the respective portions of 8 percent, 7 percent, and 85 percent. From 1951 to 1964, James received approximately 26 percent of Cherokee's net profits.
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Cherokee, a closely held warehousing corporation, had paid its general manager, James, under an incentive compensation arrangement since its incorporation in 1951. James, a trust for his sister's benefit, and his father held all of Cherokee's stock in the respective portions of 8 percent, 7 percent, and 85 percent. From 1951 to 1964, James received approximately 26 percent of Cherokee's net profits. During the years after the only revision in the compensation arrangement in 1964, including the years in issue, James received approximately 34 percent of Cherokee's net profits. While Cherokee…
1Opinion of the Court
James D. Kennedy, Jr., and Dorothy H. Kennedy, Petitioners v. Commissioner of Internal Revenue, Respondent; Cherokee Warehouses, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Kennedy v. Commissioner
Docket Nos. 9849-77, 9850-77
United States Tax Court
72 T.C. 793; 1979 U.S. Tax Ct. LEXIS 79;
August 7, 1979, Filed
Decisions will be entered under Rule 155.
Cherokee, a closely held warehousing corporation, had paid its general manager, James, under an incentive compensation arrangement since its incorporation in 1951. James, a trust for his sister's benefit, and his father held all…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Meneguzzo v. CommissionerUnited States Tax Court · 1965
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
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