Los Angeles Towel Serv. Co. v. Commissioner
United States Tax Court
Respondent determined a portion of salary and bonus paid by petitioner to one of its officers to be in excess of reasonable compensation for services actually rendered. Held, under the facts, he committed no error in so doing. Petitioner acquired the business and equipment of some of its competitors and allocated part of the purchase price paid therefor to "commissions." Held, the amounts so designated were capital expenditures and not deductible as business expenses.
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Respondent determined a portion of salary and bonus paid by petitioner to one of its officers to be in excess of reasonable compensation for services actually rendered. Held, under the facts, he committed no error in so doing. Petitioner acquired the business and equipment of some of its competitors and allocated part of the purchase price paid therefor to "commissions." Held, the amounts so designated were capital expenditures and not deductible as business expenses. Petitioner's alternative allegations present an inconsistent position within the meaning of section 734, I.R.C., and…
1Opinion of the Court
Los Angeles Towel Service Company, a California corporation v. Commissioner.
Los Angeles Towel Serv. Co. v. Commissioner
Docket No. 13581.
United States Tax Court
1949 Tax Ct. Memo LEXIS 76; 8 T.C.M. (CCH) 847; T.C.M. (RIA) 49228;
September 14, 1949
Respondent determined a portion of salary and bonus paid by petitioner to one of its officers to be in excess of reasonable compensation for services actually rendered. Held, under the facts, he committed no error in so doing.
Petitioner acquired the business and equipment of some of its competitors and allocated part of the purchase price paid therefor…
2Cases cited7 opinions
- Leonard Refineries, Inc. v. CommissionerUnited States Tax Court · 1948
- Zellerbach Paper Co. v. CommissionerUnited States Tax Court · 1947
- Carithers-Wallace-Courtenay v. CommissionerUnited States Tax Court · 1945
- Rosemary Mfg. Co. v. CommissionerUnited States Tax Court · 1947
- Appeal of the Pevely Dairy Co.United States Board of Tax Appeals · 1925
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Metropolitan Laundry Co. v. United StatesDistrict Court, N.D. California · 1951