Legal Opinion

Barto Co. v. Commissioner

United States Board of Tax Appeals

Decided January 15, 1931No. Docket Nos. 33474, 40501Published

1. Evidence fails to show that amounts claimed as deductions from income in the several taxable years here involved as ordinary and necessary expenses were reasonable compensation for personal services rendered in such years. 2. Certain amounts due officers of the petitioner as interest on their credit balances on the books and settled in the several taxable years by credit and debit book entries are not proper deductions from the income of a corporation on a cash receipts…

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1. Evidence fails to show that amounts claimed as deductions from income in the several taxable years here involved as ordinary and necessary expenses were reasonable compensation for personal services rendered in such years. 2. Certain amounts due officers of the petitioner as interest on their credit balances on the books and settled in the several taxable years by credit and debit book entries are not proper deductions from the income of a corporation on a cash receipts and disbursements basis.

1Opinion of the Court

THE BARTO CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Barto Co. v. Commissioner

Docket Nos. 33474, 40501.

United States Board of Tax Appeals

21 B.T.A. 1197; 1931 BTA LEXIS 2238;

January 15, 1931, Promulgated

1. Evidence fails to show that amounts claimed as deductions from income in the several taxable years here involved as ordinary and necessary expenses were reasonable compensation for personal services rendered in such years.

2. Certain amounts due officers of the petitioner as interest on their credit balances on the books and settled in the several taxable years by credit…

2Cases cited4 opinions

  1. Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
  2. United States v. Philadelphia Knitting Mills Co.Court of Appeals for the Third Circuit · 1921
  3. Barto Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Model Dairy, Inc. v. CommissionerUnited States Board of Tax Appeals · 1928

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