Express Pub. Co. v. Commissioner of Internal Rev.

SIBLEY, Circuit Judge.

On income tax returns for 1939 and 1940 the Commissioner disallowed as business expenses salaries of $261.25 per month paid Mrs. Carrie S. Frost and $166.25 per month paid Mrs. Dorsey W. Brown as First and Second Vice-President of the petitioner. The Tax Court found that Mrs. Frost rendered personal services reasonably worth $1,000 per year, but Mrs. Brown rendered none. These conclusions are contended to be erroneous under the proven facts, and an error of law is asserted in the rejection of opinion evidence as to the reasonable value of the services.

The Tax Court finds…