The Barton-Gillet Company, a Corporation v. Commissioner of Internal Revenue

This is an income tax case. The Commissioner determined deficiencies in the corporation income tax of the petitioner for the taxable years ended December 31, 1964, 1965 and 1966. The Commissioner determined that certain amounts paid (commissions, salaries and contributions to a qualified profit sharing trust) by petitioner to its chief executive officer, and claimed to be fully deductible for income tax purposes as a trade or business expense, were unreasonable and excessive within the meaning of Internal Revenue Code of 1954, Sec. 162(a) (1) and the pertinent regulations.

The sole question on…