Model Dairy, Inc. v. Commissioner
United States Board of Tax Appeals
In January, 1922, petitioner authorized additional salaries for its officers and employees for the years 1920 and 1921 and paid such additional compensation in the years 1922 and 1923. Held, that in the absence of proof that the combined regular and additional salaries paid in 1922 and 1923 were no more than reasonable compensation for personal services rendered, the payments so made are not deductible from petitioner's income in the respective years as ordinary and…
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In January, 1922, petitioner authorized additional salaries for its officers and employees for the years 1920 and 1921 and paid such additional compensation in the years 1922 and 1923. Held, that in the absence of proof that the combined regular and additional salaries paid in 1922 and 1923 were no more than reasonable compensation for personal services rendered, the payments so made are not deductible from petitioner's income in the respective years as ordinary and necessary operating expenses.
1Opinion of the Court
MODEL DAIRY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Model Dairy, Inc. v. Commissioner
Docket No. 19332.
United States Board of Tax Appeals
13 B.T.A. 545; 1928 BTA LEXIS 3233;
September 25, 1928, Promulgated
In January, 1922, petitioner authorized additional salaries for its officers and employees for the years 1920 and 1921 and paid such additional compensation in the years 1922 and 1923. Held, that in the absence of proof that the combined regular and additional salaries paid in 1922 and 1923 were no more than reasonable compensation for personal services rendered, the…
2Cases cited1 opinion
- Model Dairy, Inc. v. CommissionerUnited States Board of Tax Appeals · 1928