Miles-Conley Co. v. Commissioner
United States Tax Court
1. Held, under facts of record, that respondent erred in allocating to petitioner all of the net income of a sole proprietorship formed by petitioner's controlling stockholder, under section 45, Internal Revenue Code. 2. Held, under facts of record, that respondent did not err in disallowing certain parts of deductions claimed by petitioner as reasonable compensation for the services of its president.
1Opinion of the Court
OPINION.
Kern, Judge:
The first and more interesting question involved in this proceeding is whether the respondent erred in allocating to petitioner corporation all of the net income of a sole proprietorship carried on by petitioner’s controlling stockholder, A. Carlisle Miles, doing business as Carlisle Miles & Co., for the taxable year ended August 31, 1944. Respondent determined that petitioner’s income for the taxable year should be increased by the amount of the net income of the proprietorship under the provisions of section 45 of the Internal Revenue Code.1
Respondent’s principal…
2Cases cited1 opinion
- Higgins v. SmithSupreme Court of the United States · 1940
3Cited by72 opinions
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Levenson & Klein, Inc. v. CommissionerUnited States Tax Court · 1977
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
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