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CHARLES McCANDLESS TILE SERVICE v. UNITED STATES

No. 30-67

422 F.2d 1336 (1970)

CHARLES McCANDLESS TILE SERVICE v. The UNITED STATES.

United States Court of Claims.

March 20, 1970.

Attorney(s) appearing for the Case

John A. Harvey, III, Santa Ana, Cal., for plaintiff.

Joseph Kovner, Washington, L. C., with whom was Asst. Atty. Gen. Johnnie M. Walters, for defendant, Philip R. Miller and John J. Kilgariff, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON and NICHOLS, Judges.

OPINION*

LARAMORE, Judge.

This is an action to recover Federal income taxes paid by plaintiff for the fiscal years ended June 30, 1963, 1964 and 1965. The issue presented involves the extent to which amounts paid by plaintiff during the years in question to its two principal officer-stockholders are deductible for tax purposes as reasonable compensation. The relevant facts, set forth at length in succeeding findings, are recited...

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