Wm. J. Lemp Brewing Co. v. Commissioner
United States Tax Court
1. Petitioner during the taxable periods involved was a personal holding company. 2. Petitioner has failed to establish that its failure to file personal holding company returns, Form 1120-H, was due to reasonable cause and the imposition of the 25 per cent penalty for each of the taxable years involved is sustained. 3. The amounts the petitioner is entitled to deduct as reasonable compensation paid to its two officers in the respective taxable years in question determined.…
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1. Petitioner during the taxable periods involved was a personal holding company. 2. Petitioner has failed to establish that its failure to file personal holding company returns, Form 1120-H, was due to reasonable cause and the imposition of the 25 per cent penalty for each of the taxable years involved is sustained. 3. The amounts the petitioner is entitled to deduct as reasonable compensation paid to its two officers in the respective taxable years in question determined. 4. The amounts deductible as ordinary and necessary business expenses representing promotional and travel expenditures…
1Opinion of the Court
Wm. J. Lemp Brewing Company, a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Wm. J. Lemp Brewing Co. v. Commissioner
Docket No. 30136
United States Tax Court
18 T.C. 586; 1952 U.S. Tax Ct. LEXIS 163;
June 20, 1952, Promulgated
Decision will be entered under Rule 50.
1. Petitioner during the taxable periods involved was a personal holding company.
2. Petitioner has failed to establish that its failure to file personal holding company returns, Form 1120-H, was due to reasonable cause and the imposition of the 25 per cent penalty for each of the taxable years involved is…
2Cases cited16 opinions
- Wilson v. CommissionerUnited States Tax Court · 1948
- Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
- Tompkins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1938
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Wilson Bros. & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1948
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