Brooklyn Radio Service Corp. v. Commissioner
United States Board of Tax Appeals
A corporation agreed to pay its president a salary measured by a percentage of its net sales for the taxable year, with the understanding that the amount would not be paid as long as the corporation was indebted to finance companies on account of its own insufficiency of working capital or to any banks, and in no event until after the taxable year, and with the further understanding that the amount due would be subordinated by him to the indebtedness of all other creditors…
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A corporation agreed to pay its president a salary measured by a percentage of its net sales for the taxable year, with the understanding that the amount would not be paid as long as the corporation was indebted to finance companies on account of its own insufficiency of working capital or to any banks, and in no event until after the taxable year, and with the further understanding that the amount due would be subordinated by him to the indebtedness of all other creditors of the corporation. Held, while the time of payment was uncertain, the obligation to pay the salary (there having been…
1Opinion of the Court
BROOKLYN RADIO SERVICE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Brooklyn Radio Service Corp. v. Commissioner
Docket No. 61229.
United States Board of Tax Appeals
31 B.T.A. 269; 1934 BTA LEXIS 1123;
October 9, 1934, Promulgated
A corporation agreed to pay its president a salary measured by a percentage of its net sales for the taxable year, with the understanding that the amount would not be paid as long as the corporation was indebted to finance companies on account of its own insufficiency of working capital or to any banks, and in no event until after the taxable…
2Cases cited1 opinion
- Brooklyn Radio Service Corp. v. CommissionerUnited States Board of Tax Appeals · 1934