United States Tenth Circuit
EBERL'S CLAIM SERV., INC. v. COMM'R OF INTERNAL REVENUE, 99-9033
Payment to corporation's sole shareholder of a salary that depleted corporation of almost all its value is unreasonable and part of payment may be viewed as a dividend.
Appellate Information
- Decided 05/04/2001
- Published 05/04/2001
Judges
- LUCERO, Circuit Judge., Before LUCERO, McKAY and MURPHY, Circuit Judges.
Court
- United States Tenth Circuit
Counsel
- For Appellant:
- Mark R. Kravitz (Joseph A. SanFilippo, Jr., Wiggin & Dana, New Haven, CT and John D. Moats, Englewood, CO, with him on the briefs), Wiggin & Dana, New Haven, CT, for the Petitioner-Appellant.
- For Appellees:
- Joan I. Oppenheimer (Gilbert S. Rothenberg with her on the brief), Tax Division, Department of Justice, Washington, DC, for the Respondent-Appellee.