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PENLEY REALTY CORP. v. COMMISSIONER

Docket Nos. 70944, 70945.

19 T.C.M. 1005 (1960)

T.C. Memo. 1960-193

Penley Realty Corp. v. Commissioner. Vernon Avenue Realty Corp. v. Commissioner.

United States Tax Court.

Filed September 21, 1960.

Attorney(s) appearing for the Case

Alexander M. Inselman, Esq., 261 Broadway, New York, N. Y., for the petitioners. William F. Chapman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined the following deficiencies in income tax for the calendar year 1953:

  Penley Realty Corp.............   $4,500.00
  Vernon Avenue Realty Corp. ....      494.11

The issue is whether the amounts of $18,000 and $2,400 paid by petitioners Penley Realty Corporation and Vernon Avenue Realty Corporation, respectively, to their officer-stockholders in 1953 constituted "reasonable" compensation...

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