· 8/16/1968
Pacific Grains, Inc., an Oregon Corporation v. Commissioner of Internal Revenue
Citations
- 399 F.2d 603
- 22 A.F.T.R.2d (RIA) 5413
- 1968 U.S. App. LEXIS 5772
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- stating that the reasonableness of compensation is a question of fact to be determined on the basis of all the facts and circumstances
- stating that the reasonableness of compensation is a question of fact to be determined on the basis of all the facts and circumstances
- stating that the reasonableness of compensation is a question of fact to be determined on the basis of all the facts and circumstances
- stating that the reasonableness of compensation is a question of fact to be determined on the basis of all the facts - 92 - and circumstances
- finding the failure of a successful company “to pay any dividends while radically increasing the compensation of its sole shareholder” is particularly telling of a disguised dividend
- court found that corporate president was not underpaid in part because taxpayer's board did not state that some part of the payments were for his prior services
Source: CourtListener parenthetical corpus (CC0).
Judges: Hamley, Duniway, Byrne
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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