Legal Opinion

Leedy-Glover Realty & Insurance Co., Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided December 15, 1950No. 13234PublishedCited by 23 opinions

1Per curiam

This Court has held that the question of what constitutes a reasonable allowance for salary expense under the provisions of Section 23(a) (1) (A) of the Internal Revenue Code and the applicable treasury regulations is a question of fact under the circumstances of each particular case. See Gem Jewelry Co. v. Commissioner, 5 Cir., 165 F.2d 991; Commercial Iron Works v. Commissioner, 5 Cir., 166 F.2d 221, 223; Canal Navigation & Trading Co. v. Commissioner, 5 Cir., 168 F.2d 512; Title 26 U.S.C.A. § 23(a) (1) (A).

Here, the Tax Court has fixed an amount properly deductible as salaries for each of…

2Cases cited5 opinions

  1. Commercial Iron Works v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1948
  2. J. H. Robinson Truck Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
  3. Gem Jewelry Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
  4. Crescent Bed Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1943
  5. Canal Navigation & Trading Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1948

3Cited by23 opinions

  1. Young & Rubicam, Inc. v. The United StatesUnited States Court of Claims · 1969
  2. Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
  3. Burford-Toothaker Tractor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  4. Kerry Inv. Co. v. CommissionerUnited States Tax Court · 1972
  5. Golden Construction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955

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