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CAPITOL FINANCE COMPANY, INC. v. COMMISSIONER

Docket No. 7168-70.

31 T.C.M. 1021 (1972)

T.C. Memo. 1972-206

Capitol Finance Company, Inc. v. Commissioner.

United States Tax Court.

Filed September 25, 1972.

Attorney(s) appearing for the Case

Towner Leeper, 700 American Bank of Commerce Bldg., El Paso, Tex., for the petitioner. Paul H. Waldman, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent asserted deficiencies in petitioner's income tax for the years 1967, 1968, and 1969 in the respective amounts of $14,880.00, $17,424.00, and $15,915.42.

The sole issue is whether amounts paid by petitioner to an officer-stockholder were reasonable compensation for services rendered so as to be deductible under section 162(a)(1), Internal...

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