Legal Opinion

Fifth Ave. Coach Lines,Inc. v. Commissioner

United States Tax Court

Decided February 27, 1959No. Docket No. 61646Published

1. Petitioner's past president had served petitioner for many years and during a period of severe difficulties, when the petitioner attempted to acquire bus franchises, without a salary increase. He played a prominent role in securing bus franchises for petitioner; the petitioner's bus operation resulted in large profits for the petitioner, which had been suffering heavy losses for years. Thereafter, the president received a substantial wage increase.

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1. Petitioner's past president had served petitioner for many years and during a period of severe difficulties, when the petitioner attempted to acquire bus franchises, without a salary increase. He played a prominent role in securing bus franchises for petitioner; the petitioner's bus operation resulted in large profits for the petitioner, which had been suffering heavy losses for years. Thereafter, the president received a substantial wage increase. Neither the president nor his wife owned any of petitioner's stock. Held, payments by the petitioner to its past president's widow equal in…

1Opinion of the Court

Fifth Avenue Coach Lines, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Fifth Ave. Coach Lines,Inc. v. Commissioner

Docket No. 61646

United States Tax Court

31 T.C. 1080; 1959 U.S. Tax Ct. LEXIS 228;

February 27, 1959, Filed

Decision will be entered under Rule 50.

1. Petitioner's past president had served petitioner for many years and during a period of severe difficulties, when the petitioner attempted to acquire bus franchises, without a salary increase. He played a prominent role in securing bus franchises for petitioner; the petitioner's bus operation resulted in large…

Also in this document: Dissent; Concurring in part, dissenting in part.

2Cases cited44 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. United States v. AndersonSupreme Court of the United States · 1926
  4. Lucas v. American Code Co.Supreme Court of the United States · 1930
  5. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944

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