Macon Oil & Gas Co. v. Commissioner
United States Board of Tax Appeals
1. Additional compensation of officers and employees for services in prior years held reasonable and proper and deductible from corporation's income year in which paid. 2. Losses claimed by reason of alleged worthlessness of oil and gas lease disallowed for lack of evidence. 3. Held that under the provisions of section 204(c)(2) of the Revenue Act of 1926, the depletion deducted as to oil and gas properties may not be based on the profits received from the sale of the…
Read the full summary
1. Additional compensation of officers and employees for services in prior years held reasonable and proper and deductible from corporation's income year in which paid. 2. Losses claimed by reason of alleged worthlessness of oil and gas lease disallowed for lack of evidence. 3. Held that under the provisions of section 204(c)(2) of the Revenue Act of 1926, the depletion deducted as to oil and gas properties may not be based on the profits received from the sale of the properties themselves.
1Opinion of the Court
*58OPINION.
Black:
The first error assigned relates to the disallowance, of $20,000 claimed by petitioner as a deduction for salaries paid to officers and employees during the fiscal year under consideration. The facts with reference to this transaction have been fully stated in our findings of fact.
In Lucas v. Ox Fibre Brush Co., 281 U. S. 115, the Supreme Court had before it a similar question arising under the corresponding section of the Revenue #Act of 1918, which is identical with those here involved and the court there said:
The payments in the present instance were actually made in the year…
2Cases cited1 opinion
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
3Cited by9 opinions
- Brountas v. CommissionerUnited States Tax Court · 1979
- Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1982
- Consumers Natural Gas Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Fritz v. CommissionerUnited States Board of Tax Appeals · 1933
- Brountas v. CommissionerUnited States Tax Court · 1979
4 more not listed; retrieve them via the Exa API.