Legal Opinion

R. P. Farnsworth & Co., Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided April 10, 1953No. 14160PublishedCited by 19 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

The question presented is whether salaries paid by petitioner to its seven executive officers, plus contributions made by it to a pension trust fund for the benefit of the same officers, were deductible as reasonable compensation for services rendered the corporation by each of them during the years 1944 and 1945, as contemplated by Section 23(a) (1) (A) and (p) (1) (D) of the Internal Revenue Code, 26 U.S.C.A. § 23 (a) (1) (A), (p) (1) (D).

The facts as stipulated and as found by the court may be stated briefly as follows: Petitioner is the largest concern engaged in the…

2Cases cited9 opinions

  1. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  2. Roth Office Equipment Co. v. GallagherCourt of Appeals for the Sixth Circuit · 1949
  3. Capitol-Barg Dry Cleaning Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  4. Gillette's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
  5. Wright-Bernet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949

4 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
  2. Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
  3. Davis v. Alabama Power CompanyDistrict Court, N.D. Alabama · 1974
  4. Baltimore Dairy Lunch, Inc., a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1956
  5. Raymond Tank and Elizabeth Tank v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959

14 more not listed; retrieve them via the Exa API.

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