Vegetable Farms, Inc. v. Commissioner
United States Tax Court
1. On the facts, held, respondent's determinations as to reasonableness of salaries of depreciation on machinery and equipment during the taxable years and reasonable allowance for salaries in computing base period net income of petitioner's predecessor are sustained. 2. Held, under the facts of record, advances made to petitioner on open account by its officers are not includible in equity invested capital in determining petitioner's excess profits tax liability.
1Opinion of the Court
OPINION.
Arnold, Judge:
Petitioner contests respondent’s disallowance of deductions taken for salaries paid its officer-stockholders in the taxable years ended October 31, in 1942, 1943, and 1944. At a meeting of the directors of the petitioner on April 27, 1941, salaries of $500, per month each were authorized to be paid Tamura and Matsuno, effective from November 1, 1940. These salaries were paid them through April, 1942. On September 12, 1942, the board of directors authorized payment of $10,000 each to Tamura and Matsuno for services rendered as officers prior to their evacuation.…
2Cases cited3 opinions
- Leonard Refineries, Inc. v. CommissionerUnited States Tax Court · 1948
- Flint Nortown Theatre Co. v. CommissionerUnited States Tax Court · 1945
- Tri-State Realty Co. v. CommissionerUnited States Tax Court · 1949
3Cited by1 opinion
- Vegetable Farms, Inc. v. CommissionerUnited States Tax Court · 1950