Heatbath Corp. v. Commissioner
United States Tax Court
1. Deduction -- Expense -- Compensation. -- Reasonable allowances determined for salaries or other compensation for personal services rendered to a corporation by its officers. 2. Deduction -- Expense -- Royalties. -- A corporation is entitled to deduct reasonable amounts representing fair compensation paid or accrued to two of its controlling stockholders for the use of their invention, in spite of their having granted the corporation a royalty-free license, where the…
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1. Deduction -- Expense -- Compensation. -- Reasonable allowances determined for salaries or other compensation for personal services rendered to a corporation by its officers. 2. Deduction -- Expense -- Royalties. -- A corporation is entitled to deduct reasonable amounts representing fair compensation paid or accrued to two of its controlling stockholders for the use of their invention, in spite of their having granted the corporation a royalty-free license, where the parties contemplated and intended to agree upon such compensation after a trial period. 3. Deduction -- Unpaid Expense --…
1Opinion of the Court
Heatbath Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Heatbath Corp. v. Commissioner
Docket No. 17563
United States Tax Court
14 T.C. 332; 1950 U.S. Tax Ct. LEXIS 265;
March 1, 1950, Promulgated
Decision will be entered under Rule 50.
1. Deduction -- Expense -- Compensation. -- Reasonable allowances determined for salaries or other compensation for personal services rendered to a corporation by its officers.
2. Deduction -- Expense -- Royalties. -- A corporation is entitled to deduct reasonable amounts representing fair compensation paid or accrued to two of its…
2Cases cited7 opinions
- De Forest Radio Telephone Co. v. United StatesSupreme Court of the United States · 1927
- P. Dougherty Co. v. CommissionerUnited States Tax Court · 1945
- Anthony P. Miller, Inc. v. CommissionerUnited States Tax Court · 1946
- Akron Welding & Spring Co. v. CommissionerUnited States Tax Court · 1948
- Home Guaranty Abstract Co. v. CommissionerUnited States Tax Court · 1947
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