Levenson & Klein, Inc. v. Commissioner
United States Tax Court
Held, based on all the facts presented, compensation paid by petitioner Levenson & Klein, Inc., to its president/chairman of the board was reasonable. Held, further, rent paid by Levenson & Klein, Inc., for its Route 40 West store determined to be an ordinary and necessary business expense required to be paid as a condition for the continued use and possession of the premises.
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Held, based on all the facts presented, compensation paid by petitioner Levenson & Klein, Inc., to its president/chairman of the board was reasonable. Held, further, rent paid by Levenson & Klein, Inc., for its Route 40 West store determined to be an ordinary and necessary business expense required to be paid as a condition for the continued use and possession of the premises. Held, further, deductibility of the corporation's legal and professional fees determined; such fees not constituting preferential dividends to petitioners William and Gloria Levenson.
1Opinion of the Court
Sterrett, Judge:
Respondent determined deficiencies in the income tax of petitioners William and Gloria Levenson for the calendar year 1972 in the amount of $2,074, and of petitioner Levenson & Klein, Inc., for the taxable years ended January 31, 1971, 1972, and 1973 in the respective amounts of $19,923.48, $30,242.15, and $33,292.85. These cases have been consolidated for trial due to the relationship of the petitioners and the continuity of the facts involved. Concessions having been made by the parties, the issues remaining for decision are as follows;(1) Whether the respondent erred in…
2Cases cited16 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Place v. CommissionerUnited States Tax Court · 1951
- Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1976
- Pepsi-Cola Bottling Co. v. CommissionerUnited States Tax Court · 1974
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- Eller v. CommissionerUnited States Tax Court · 1981
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