Jerry Lipps, Inc. v. Commissioner
United States Tax Court
Respondent claimed increased deficiencies by amendments to answers. Held: (1) The Court has jurisdiction over the disputes as to these increased deficiencies. Sec. 6214(a), I.R.C. 1954. The burden of proof is on respondent as to these items. During 1975 and 1976 petitioner-husband (Lipps) owned substantially all of corporations ARI and JLI.
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Respondent claimed increased deficiencies by amendments to answers. Held: (1) The Court has jurisdiction over the disputes as to these increased deficiencies. Sec. 6214(a), I.R.C. 1954. The burden of proof is on respondent as to these items. During 1975 and 1976 petitioner-husband (Lipps) owned substantially all of corporations ARI and JLI. In 1975 and 1976 JLI paid amounts to ARI for "management services" performed by Lipps; ARI paid amounts to Lipps for "management services". Also, JLI paid amounts to Lipps for "terminal agent's fees". Held: (2) Reasonable compensation for Lipps' services…
1Opinion of the Court
JERRY LIPPS, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jerry Lipps, Inc. v. Commissioner
Docket Nos. 11452-78, 11453-78, 7990-79, 14020-79, 14021-79, 1368-80
United States Tax Court
T.C. Memo 1990-293; 1990 Tax Ct. Memo LEXIS 311; 59 T.C.M. (CCH) 849; T.C.M. (RIA) 90293;
June 12, 1990, Filed
Decisions will be entered under Rule 155.
Respondent claimed increased deficiencies by amendments to answers.
Held: (1) The Court has jurisdiction over the disputes as to these increased deficiencies. Sec. 6214(a), I.R.C. 1954. The burden of proof is on respondent as to these…
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