Legal Opinion
Commissioner of Internal Revenue v. R. J. Reynolds Tobacco Company
Court of Appeals for the Fourth Circuit
Decided October 6, 1958No. 7659_1PublishedCited by 13 opinions
1Opinion of the Court
SOBELOFF, Chief Judge.
In the years 1949 and 1950, the R. J. Reynolds Tobacco Company claimed deductions in its income tax returns for amounts distributed to its employees pursuant to one of its by-laws. Although the employees shared in the fund in proportion to their stockholdings in the company, it claimed that the payments were compensation for services and for that reason deductible as an ordinary and necessary expense. The Commissioner of Internal Revenue disallowed the claims and the taxpayer sought review in the Tax Court. From the judgment of that court allowing deductions for part of…
2Cases cited12 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- W. Horace Williams, Sr., and Viola Bloch Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1957
- Taylor v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1934
7 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Lesly Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Harbin v. CommissionerUnited States Tax Court · 1963
- Nannie v. Compton v. United States of AmericaCourt of Appeals for the Fourth Circuit · 1964
- Bianchi v. CommissionerUnited States Tax Court · 1976
- Sitnick v. United StatesDistrict Court, D. Maryland · 1965
8 more not listed; retrieve them via the Exa API.