Laure v. Commissioner
United States Tax Court
Laure was sole stockholder of both W-L Molding Co. and Lakala Aviation, Inc. Both Laure and W-L Molding advanced funds to Lakala. Lakala suffered losses and its business was discontinued, purportedly through a merger into W-L Molding, which assumed its obligations.
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Laure was sole stockholder of both W-L Molding Co. and Lakala Aviation, Inc. Both Laure and W-L Molding advanced funds to Lakala. Lakala suffered losses and its business was discontinued, purportedly through a merger into W-L Molding, which assumed its obligations. Held: 1. Salary paid to Laure by W-L Molding Co. was reasonable compensation for services rendered and is fully deductible by W-L Molding Co. 2. Purported merger of Lakala Aviation, Inc., into W-L Molding Co. did not qualify as a statutory merger under sec. 368(a)(1)(A), I.R.C. 1954, and W-L Molding Co. may not deduct premerger net…
1Opinion of the Court
Drennen, Judge:
In these consolidated cases respondent determined deficiencies in Federal income taxes as follows:
Docket No. Petitioner Year Deficiency
1517-76 George R. Laure and Esther L. Laure ...1971 $9,885.00
1972 188,205.00
1518-76 W-L Molding Co.6/30/72 57,320.11
6/30/73 97,328.60
Various issues have been settled, leaving for our decision these main questions:(1) Whether under section 162(a)(1), I.R.C. 1954,1 amounts deducted by petitioner W-L Molding Co. as compensation for George R. Laure, its president and treasurer, were for services rendered and reasonable in amount.(2) Whether…
2Cases cited25 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
20 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Elliotts, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Kean v. CommissionerUnited States Tax Court · 1988
- Appeal of George R. Laure and Esther L. Laure. W-L Molding Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
- Davis v. CommissionerUnited States Tax Court · 1995
- B. B. Rider Corp. v. CommissionerUnited States Tax Court · 1982
23 more not listed; retrieve them via the Exa API.