Aries Communs., Inc. v. Comm'r
United States Tax Court
R determined that the compensation P paid to E, its employee and owner, was unreasonable and disallowed its deduction for the tax year ending Aug. 31, 2004. Held: E's compensation was reasonable and deductible under I.R.C. sec. 162 to the extent determined herein. Held, further, P is liable for a portion of the I.R.C. sec. 6662(a) accuracy-related penalty as redetermined in this opinion.
1Opinion of the Court
ARIES COMMUNICATIONS INC. & SUBS., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Aries Communs., Inc. v. Comm'r
Docket No. 27483-10.
United States Tax Court
T.C. Memo 2013-97; 2013 Tax Ct. Memo LEXIS 111; 105 T.C.M. (CCH) 1585;
April 10, 2013, Filed
Decision will be entered under Rule 155.
R determined that the compensation P paid to E, its employee and owner, was unreasonable and disallowed its deduction for the tax year ending Aug. 31, 2004.
Held: E's compensation was reasonable and deductible under I.R.C. sec. 162 to the extent determined herein.
Held, further, P is liable for a…
2Cases cited28 opinions
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
- Kumho Tire Co. v. CarmichaelSupreme Court of the United States · 1999
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
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