Legal Opinion

Glenshaw Glass Co. v. Commissioner

United States Tax Court

Decided October 15, 1946No. Docket No. 6994UnpublishedCited by 1 opinion

The salaries and bonuses, totaling $67,000, paid by petitioner as compensation to its three executives, is held to be properly deductible as being reasonable compensation for the fiscal year ending September 30, 1941. The deduction of $60,497.85, in addition to the total of $67,000 fixed salaries paid to the same executives in the fiscal year ending September 30, 1942, is denied because petitioner has not carried its burden of establishing that such amount was not, in fact,…

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The salaries and bonuses, totaling $67,000, paid by petitioner as compensation to its three executives, is held to be properly deductible as being reasonable compensation for the fiscal year ending September 30, 1941. The deduction of $60,497.85, in addition to the total of $67,000 fixed salaries paid to the same executives in the fiscal year ending September 30, 1942, is denied because petitioner has not carried its burden of establishing that such amount was not, in fact, distributed as profits in the guise of compensation.

1Opinion of the Court

Glenshaw Glass Company, Inc., a corporation v. Commissioner.

Glenshaw Glass Co. v. Commissioner

Docket No. 6994.

United States Tax Court

1946 Tax Ct. Memo LEXIS 58; 5 T.C.M. (CCH) 864; T.C.M. (RIA) 46245;

October 15, 1946

The salaries and bonuses, totaling $67,000, paid by petitioner as compensation to its three executives, is held to be properly deductible as being reasonable compensation for the fiscal year ending September 30, 1941. The deduction of $60,497.85, in addition to the total of $67,000 fixed salaries paid to the same executives in the fiscal year ending September 30, 1942, is denied…

2Cases cited3 opinions

  1. L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Long Island Drug Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Joseph Goodnow & Co. v. CommissionerUnited States Board of Tax Appeals · 1927

3Cited by1 opinion

  1. Smith v. Manning (Two Cases)Court of Appeals for the Third Circuit · 1951

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