Legal Opinion
Alpha Medical, Inc., Formerly Known as Alpha Medical Management, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 19, 1999No. 98-1406PublishedCited by 10 opinions
1Opinion of the Court
MERRITT, Circuit Judge.
During 1990, Taxpayer Alpha Medical Management, Inc., a medical management corporation in Tennessee, paid Mr. William Rogers, its president, director, and sole shareholder, compensation totaling $4,439,-180 and claimed a deduction for that amount on its tax return for that year. Upon audit of that return, the Internal Revenue Service determined that the compensation paid to Rogers, to the extent it exceeded $400,000, was unreasonable and, therefore, nondeductible. The IRS accordingly determined a deficiency in taxpayer’s 1990 income of $1,376,520. In addition, the IRS…
2Cases cited16 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Welch v. HelveringSupreme Court of the United States · 1933
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
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3Cited by10 opinions
- Menard, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 2009
- Labelgraphics, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Eberl's Claim Service, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2001
- Garavaglia v. Comm'rUnited States Tax Court · 2011
- Miller & Sons Drywall, Inc. v. Comm'rUnited States Tax Court · 2005
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