University Chevrolet Co. v. Commissioner
United States Tax Court
Deduction -- Compensation -- Section 23 (a) (1) (A). -- The amount characterized as compensation under a bonus-stock purchasing arrangement adopted by General Motors to obtain and establish dealers is not determinative of reasonable compensation of the same officer after he becomes owner of all of the stock.
1Opinion of the Court
OPINION.
Murdock, Judge:
The petitioner has claimed a deduction of $27,-655.73 under section 23 (a) (1) (A) of the Internal Revenue Code which allows a deduction “including a reasonable allowance for salaries or other compensation for personal services actually rendered.” The determination of the Commissioner that a reasonable allowance for compensation of Davis was $14,643.24, and not more, is presumed to be correct until evidence is introduced showing that a reasonable allowance is a larger amount.
Counsel for the petitioner takes the position that the salary and bonus computed for 1946 under…
2Cited by4 opinions
- Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
- City Chevrolet Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
- Owensby & Kritikos, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1987
- University Chevrolet Co. v. CommissionerUnited States Tax Court · 1951