Atlumor Mfg. Co. v. Commissioner
United States Tax Court
1. Deduction -- Expense -- Compensation -- Salary Stabilization. -- Reasonable allowance for salaries or other compensation for personal services actually rendered determined. 2. Excess Profits Tax -- Equity Invested Capital -- Accumulated Earnings and Profits -- Taxes for a Prior Year. -- A taxpayer on an accrual basis must eliminate from its earnings and profits as of the beginning of the taxable year its income and excess profits taxes for the preceding year, in…
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1. Deduction -- Expense -- Compensation -- Salary Stabilization. -- Reasonable allowance for salaries or other compensation for personal services actually rendered determined. 2. Excess Profits Tax -- Equity Invested Capital -- Accumulated Earnings and Profits -- Taxes for a Prior Year. -- A taxpayer on an accrual basis must eliminate from its earnings and profits as of the beginning of the taxable year its income and excess profits taxes for the preceding year, in determining its equity invested capital under section 718, I. R. C. 3. Excess Profits Tax -- Abnormal Income -- Lack of Proof. --…
1Opinion of the Court
OPINION.
Murdock, Judge:
The parties have not called the attention of the Court to any provision of the Stabilization Act of 1942 or to any orders or regulations of the President issued pursuant thereto which might have any effect upon this case. The respondent does not argue that the petitioner, under its oral agreement with Moore and Welmers, had a right to accrue the percentages during 1943 and 1944, and he does not argue that there was any prohibition under the Stabilization Act against the accrual of those obligations for 1943 and 1944 in 1945. He “agrees that the proper year of accrual…
2Cases cited9 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
4 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
- Joan Carol Corp. v. CommissionerUnited States Tax Court · 1949
- Caldwell-Clements, Inc. v. CommissionerUnited States Tax Court · 1957
- Woodlawn Park Cemetery Co. v. CommissionerUnited States Tax Court · 1951
- E. W. Williams Publications, Inc. v. CommissionerUnited States Tax Court · 1955
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