I. Putnam, Inc. v. Commissioner
United States Tax Court
Petitioner is a New York corporation incorporated in 1925. It began business in a small way which increased as time went on, and it became prosperous. It had two stockholders, one of whom was Israel Putnam, and much of the success of the corporation was due to his services. In 1940, because of his age and failing health, he retired from active duties.
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Petitioner is a New York corporation incorporated in 1925. It began business in a small way which increased as time went on, and it became prosperous. It had two stockholders, one of whom was Israel Putnam, and much of the success of the corporation was due to his services. In 1940, because of his age and failing health, he retired from active duties. His salary was continued at reduced rates to the time of his death on June 6, 1942. He was receiving at the time of his death $ 6,500 per annum, payable weekly. Pursuant to resolutions adopted prior to Putnam's death, the payments of $ 6,500 per…
1Opinion of the Court
OPINION.
Black, Judge:
The petitioner states in its brief the only issue which we have here to decide, as follows:
On its returns for 1944 and 1945 the taxpayer deducted as an expense a pension paid to the widow of its deceased president and co-founder in the amount of $6500 in 1944 and $5750 in 1945. The Commissioner of Internal Revenue has disallowed these items, asserting that they are improper deductions. The taxpayer takes exception to this disallowance.
The question for decision is:
Was the taxpayer correct in deducting these pensions as ordinary and necessary business expenses?
The…
2Cases cited2 opinions
- Seavey & Flarsheim Brokerage Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Trout-Ware, Inc. v. CommissionerUnited States Tax Court · 1948
3Cited by22 opinions
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
- Barbourville Brick Co. v. CommissionerUnited States Tax Court · 1961
- Philadelphia-Baltimore Stock Exchange v. CommissionerUnited States Tax Court · 1952
- Rubber Associates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Loewy Drug Co. of Baltimore City v. United StatesDistrict Court, D. Maryland · 1964
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