Barto Co. v. Commissioner
United States Board of Tax Appeals
1. Evidence fails to show that amounts claimed as deductions from income in the several taxable years here involved as ordinary and necessary expenses were reasonable compensation for personal services rendered in such years. 2. Certain amounts due officers of the petitioner as interest on their credit balances on the books and settled in the several taxable years by credit and debit book entries are not proper deductions from the income of a corporation on a cash receipts…
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1. Evidence fails to show that amounts claimed as deductions from income in the several taxable years here involved as ordinary and necessary expenses were reasonable compensation for personal services rendered in such years. 2. Certain amounts due officers of the petitioner as interest on their credit balances on the books and settled in the several taxable years by credit and debit book entries are not proper deductions from the income of a corporation on a cash receipts and disbursements basis.
1Opinion of the Court
*1199OPINION.
Lansdon:
The petitioner claims the right to deduct in each of the taxable years the amount of salaries authorized and settled as set forth in our findings of fact, under the identical provisions of section 234 (a) (1) and (2) of the Revenue Acts of 1924 and 1926. The statutory provision relating to .salaries contains the following ⅛ its enumeration of deductions: “All the ^ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually…
2Cases cited2 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- United States v. Philadelphia Knitting Mills Co.Court of Appeals for the Third Circuit · 1921
3Cited by11 opinions
- Brewster v. CommissionerUnited States Tax Court · 1976
- Coosa Land Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Lando Products, Inc. v. CommissionerUnited States Tax Court · 1958
- Barto Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Brewster v. CommissionerUnited States Tax Court · 1976
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