Legal Opinion

Bruce Oil Co. v. Commissioner

United States Tax Court

Decided April 30, 1984No. Docket Nos. 11389-81, 11390-81, 11391-81, 11392-81, 11393-81, 11394-81, 11395-81, 11396-81, 11397-81Unpublished

During 1977, P was the president and chief operating officer of 8 corporations, which operated retail gasoline stations and related businesses. The businesses were successful, and P made all the significant business decisions and dominated the businesses.

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During 1977, P was the president and chief operating officer of 8 corporations, which operated retail gasoline stations and related businesses. The businesses were successful, and P made all the significant business decisions and dominated the businesses. However, the corporations never paid a dividend, and the alleged compensation was paid in proportion to the officers' stockholdings and was largely paid as bonuses which were declared at the end of the year and which were not paid pursuant to any formula. During 1977, some of the corporations paid certain travel and entertainment expenses.…

1Opinion of the Court

BRUCE OIL COMPANY, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bruce Oil Co. v. Commissioner

Docket Nos. 11389-81, 11390-81, 11391-81, 11392-81, 11393-81, 11394-81, 11395-81, 11396-81, 11397-81.

United States Tax Court

T.C. Memo 1984-230; 1984 Tax Ct. Memo LEXIS 441; 47 T.C.M. (CCH) 1728; T.C.M. (RIA) 84230;

April 30, 1984.

During 1977, P was the president and chief operating officer of 8 corporations, which operated retail gasoline stations and related businesses. The businesses were successful, and P made all the significant business decisions and dominated the…

2Cases cited29 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  3. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  4. Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
  5. Ashby v. CommissionerUnited States Tax Court · 1968

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