Pepsi-Cola Bottling Co. v. Commissioner
United States Tax Court
Sole executive officer of a corporation had been compensated for the years in issue under a corporate resolution which had remained unchanged for 12, 13, and 14 years, respectively, and which was no longer realistic because of related changing factors and circumstances. On consideration of all revelant facts of record, reasonable compensation for personal services actually rendered is found under sec. 162, I.R.C. 1954.
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined deficiencies in the income taxes of the petitioner for the calendar years 1968, 1969, and 1970 in the respective amounts of $35,158.05, $47,859.44, and $50,783.89. The sole issue now remaining for our decision is whether the salary paid by petitioner to its president and sole stockholder, Verla Nesbitt Joscelyn, was excessive to the extent that it exceeded $40,000 for each of the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner’s registered and principal office has at all times been located in Salina,…
2Cases cited12 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Dielectric Materials Co. v. CommissionerUnited States Tax Court · 1972
- Geiger & Peters, Inc. v. CommissionerUnited States Tax Court · 1957
- Ox Fibre Brush Co. v. BlairCourt of Appeals for the Fourth Circuit · 1929
7 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1976
- Levenson & Klein, Inc. v. CommissionerUnited States Tax Court · 1977
- Thomas v. CommissionerUnited States Tax Court · 1989
- Steel Constructors, Inc. v. CommissionerUnited States Tax Court · 1978
- Brewster v. CommissionerUnited States Tax Court · 1976
78 more not listed; retrieve them via the Exa API.