G. Angelo Co. v. Commissioner
United States Board of Tax Appeals
1. A corporation which is shown to have derived nearly all of its gross income from trading as a principal is expressly excluded in section 200 from the exemption provided under section 218(a)(e) of the Revenue Act of 1918. 2. Where compensation for the personal services of stockholders was neither authorized, paid, nor accrued, no allowance therefor can be estimated and allowed as a deduction from income. 3. Under the circumstances petitioners are held entitled to a…
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1. A corporation which is shown to have derived nearly all of its gross income from trading as a principal is expressly excluded in section 200 from the exemption provided under section 218(a)(e) of the Revenue Act of 1918. 2. Where compensation for the personal services of stockholders was neither authorized, paid, nor accrued, no allowance therefor can be estimated and allowed as a deduction from income. 3. Under the circumstances petitioners are held entitled to a comparison with respresentative concerns, as provided under section 328 of the Revenue Act of 1918.
1Opinion of the Court
G. ANGELO CO. AND G. ANGELO FRUIT CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
G. Angelo Co. v. Commissioner
Docket No. 10869.
United States Board of Tax Appeals
12 B.T.A. 460; 1928 BTA LEXIS 3535;
June 7, 1928, Promulgated
1. A corporation which is shown to have derived nearly all of its gross income from trading as a principal is expressly excluded in section 200 from the exemption provided under section 218(a)(e) of the Revenue Act of 1918.
2. Where compensation for the personal services of stockholders was neither authorized, paid, nor accrued, no allowance therefor can be…
2Cases cited1 opinion
- G. Angelo Co. v. CommissionerUnited States Board of Tax Appeals · 1928