Legal Opinion

Hunt Foods, Inc. v. Commissioner

United States Tax Court

Decided September 21, 1951No. Docket No. 20431Published

1. Petitioner's board of directors voted its two principal officers, who were minority stockholders, a fixed salary plus bonuses based upon percentages of corporate earnings. The officers devoted all their time to the corporation.

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1. Petitioner's board of directors voted its two principal officers, who were minority stockholders, a fixed salary plus bonuses based upon percentages of corporate earnings. The officers devoted all their time to the corporation. Held, the compensation paid the two officers was a reasonable allowance for the personal services actually rendered. 2. Petitioner drew sight drafts with attached bill-of-lading on its customers for merchandise sold, which it used as security with its bank to borrow money for the operation of its business. The bank collected the sight drafts and applied the proceeds…

1Opinion of the Court

Hunt Foods, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Hunt Foods, Inc. v. Commissioner

Docket No. 20431

United States Tax Court

17 T.C. 365; 1951 U.S. Tax Ct. LEXIS 89;

September 21, 1951, Promulgated

Decision will be entered under Rule 50.

1. Petitioner's board of directors voted its two principal officers, who were minority stockholders, a fixed salary plus bonuses based upon percentages of corporate earnings. The officers devoted all their time to the corporation. Held, the compensation paid the two officers was a reasonable allowance for the personal services actually…

2Cases cited28 opinions

  1. Burton v. United StatesSupreme Court of the United States · 1905
  2. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  3. Federal Reserve Bank of Richmond v. MalloySupreme Court of the United States · 1924
  4. City of Douglas v. Federal Reserve Bank of DallasSupreme Court of the United States · 1926
  5. Exchange Nat. Bank of Pittsburgh v. Third Nat. Bank of NYSupreme Court of the United States · 1884

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