United Control Corp. v. Commissioner
United States Tax Court
During the fiscal years ended August 31, 1954, 1955, and 1956, petitioner authorized officers' salaries in excess of the amounts allowed to be paid to the officers each year under credit agreements then in force between petitioner and a bank. The excess of the authorized salaries over the allowable salaries each year were subordinated to the bank loan and were accrued on petitioner's books and records as a liability to its officers.
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During the fiscal years ended August 31, 1954, 1955, and 1956, petitioner authorized officers' salaries in excess of the amounts allowed to be paid to the officers each year under credit agreements then in force between petitioner and a bank. The excess of the authorized salaries over the allowable salaries each year were subordinated to the bank loan and were accrued on petitioner's books and records as a liability to its officers. All authorized salaries during these years, whether paid or accrued on its books as a liability, were deducted as an ordinary and necessary business expense, the…
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in income tax against petitioner as follows:
Fiscal year ended Attg. SI— Ameunt
1954 _$50, 854.36
1955 _ 50,415. 03
1956 _ 25,107.43
Some of the issues hare been stipulated. The only issue remaining for our consideration is whether petitioner may deduct the excess of authorized salaries over the amount it actually paid to its four officers during each of the fiscal years in issue.
BINDINGS OB' B’AOT.
Most of the facts have been stipulated and are incorporated herein by this reference.
The United Control Corporation, hereinafter referred to as…
2Cases cited8 opinions
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Helvering v. Russian Finance & Construction CorporationCourt of Appeals for the Second Circuit · 1935
- Harrington Co. v. CommissionerUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. Brooklyn Radio Service Corp.Court of Appeals for the Second Circuit · 1935
- Smith--Lustig Paper Box Mfg. Co. v. CommissionerUnited States Tax Court · 1943
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3Cited by22 opinions
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