R. J. Nicoll Co. v. Commissioner
United States Tax Court
Held, that determined amounts paid by petitioner corporation, R. J. Nicoll Co., in 1965, 1966, and 1967, as compensation to petitioner Raymond Nicoll in excess of amounts allowed by respondent are deductible as reasonable compensation for services rendered by Raymond in prior years to corporate petitioner's predecessors, for which services Raymond was undercompensated in those prior years, applying the rule of Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); held, further,…
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Held, that determined amounts paid by petitioner corporation, R. J. Nicoll Co., in 1965, 1966, and 1967, as compensation to petitioner Raymond Nicoll in excess of amounts allowed by respondent are deductible as reasonable compensation for services rendered by Raymond in prior years to corporate petitioner's predecessors, for which services Raymond was undercompensated in those prior years, applying the rule of Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); held, further, that certain amounts paid by petitioner corporation in 1965, 1966, and 1967, as the employees' share of social security…
1Opinion of the Court
Hoyt, Judge:
The Commissioner determined deficiencies in the income tax of petitioner R. J. Nicoll Co. for the taxable year April 1, 1965, to December 31, 1965, in the amount of $1,557; for the taxable year 1966, in the amount of $2,083; and for the taxable year 1967, in the amount of $1,475. The Commissioner determined deficiencies in the income tax of petitioners Raymond Nicoll and Genevieve Nicoll for the taxable years 1965 and 1967 in the amounts of $7.78 and $116, respectively.
These cases were consolidated for all purposes upon joint motion of the parties. As certain issues have been…
2Cases cited17 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
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- La Mastro v. CommissionerUnited States Tax Court · 1979
- Cropland Chem. Corp. v. CommissionerUnited States Tax Court · 1980
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