Simplot Reversed by 9th Circuit; Control Premium for Voting Shares Incorrectly Applied
This case is the 9th Circuit Court of Appeals' decision on appeal of Estate of Simplot v. Commissioner, 112 T.C. No.13 (1999), which was abstracted in the May 1999 issue of Shannon Pratt's Business Valuation Update.
Estate of Simplot v. Commissioner (II)
Ninth Circuit reversed and ordered entry of judgment in favor of the estate on remand because the Tax Court erroneously attributed a premium to minority voting stock.
Exacto Spring v. Commissioner
At issue is the interpretation of tax law that allows a business to deduct from its income its "ordinary and necessary" business expenses.
7th Circuit Rejects Tax Court's Reasonable Compensation Test
The issue in this corporate income tax matter was whether the petitioner's deduction for the salary of its chief executive and principal owner was excessive, as asserted by the IRS.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
Value Hinges on Reasonable Compensation to an Indispensable Executive
After concessions, the issue for consideration is the amount that Exacto Spring Corp. is entitled to deduct as reasonable compensation to an indispensable executive.
Exacto Spring Corporation v. Commissioner (I)
Isue for consideration is the amount that Exacto Spring Corporation is entitled to deduct as reasonable compensation to an indispensable executive.