J. Livingston & Co. v. United States

This is a tax case. The plaintiff, a New York corporation, challenges the disallowance by the Commissioner of Internal Revenue of a portion of the total sum voted to three officials *629of the corporation for salaries in the years 1920 and 1921. Plaintiff is a close corporation; its entire capital stock, both preferred and common, is owned by the officials to whom the salaries involved were paid. In 1918 and 1919 the same officials were each receiving a salary of $15,000.00 per annum. In 1920 their salaries were increased to $30,000.00 a year, and in 1921 thdy each received $23,333.33. The return…