Garrison v. Commissioner
United States Tax Court
Petitioner Joseph Garrison was the principal stockholder-officer-employee of a corporation and received a purported $ 40,000 bonus for his services. The bonus was authorized and paid after the corporation had determined to liquidate, ceased doing business, and sold its operating assets. On audit of the corporation's return, respondent disallowed $ 15,000 of the bonus as excessive compensation and the corporation conceded the disallowance.
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Petitioner Joseph Garrison was the principal stockholder-officer-employee of a corporation and received a purported $ 40,000 bonus for his services. The bonus was authorized and paid after the corporation had determined to liquidate, ceased doing business, and sold its operating assets. On audit of the corporation's return, respondent disallowed $ 15,000 of the bonus as excessive compensation and the corporation conceded the disallowance. Held, on the particular facts, the $ 15,000 constituted a distribution in complete liquidation in respect of petitioner's stock within the meaning of sec.…
1Opinion of the Court
Joseph Garrison and Ida Garrison, Petitioners v. Commissioner of Internal Revenue, Respondent
Garrison v. Commissioner
Docket No. 5405-67
United States Tax Court
52 T.C. 281; 1969 U.S. Tax Ct. LEXIS 132;
May 15, 1969, Filed
Decision will be entered under Rule 50.
Petitioner Joseph Garrison was the principal stockholder-officer-employee of a corporation and received a purported $ 40,000 bonus for his services. The bonus was authorized and paid after the corporation had determined to liquidate, ceased doing business, and sold its operating assets. On audit of the corporation's return, respondent…
2Cases cited35 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Healy v. CommissionerSupreme Court of the United States · 1953
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
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