Astorian-Budget Publishing Co. v. Commissioner
United States Board of Tax Appeals
On its return for the taxable year petitioner deducted $2,340 as a reasonable allowance for personal services actually rendered by one of its officers and directors. Respondent allowed $600 thereof and disallowed $1,740. Held, the amount allowed by respondent constitutes a reasonable allowance for the personal services actually rendered; held, further, no part of the $1,740 disallowed id deductible as a pension, or as a payment in the nature of a pension.
1Opinion of the Court
*971OPINION.
Arnold :
The respondent contends that Dorothy Engle performed no substantial services for the petitioner which would entitle her to compensation of $2,340 for 1936. It is his contention that the $600 allowed is more than adequate for the services rendered. Petitioner contends that $1,040 represents compensation fixed by the directors for her services, and that the $1,300 paid her is in the nature of a pension pursuant to the agreement between Chessman, Aldrich, and Lamkin.
The testimony and our findings of fact show that Dorothy Engle rendered no clerical or supervisory services to the…
2Cited by7 opinions
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- Glenn-Minnich Clothing Co. v. CommissionerUnited States Tax Court · 1960
- Astorian-Budget Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1941
- H. T. Cushman Mfg. Co. v. CommissionerUnited States Tax Court · 1943
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