Legal Opinion

University Chevrolet Co., Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided December 17, 1952No. 13997_1PublishedCited by 17 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

This appeal involves income taxes for the year 1946, and is taken from a decision of the Tax Court entered June 29, 1951. 16 T.C. 1452. The question presented is whether said court’s findings of reasonable allowances for compensation for personal services for the taxpayer’s president and sole stockholder are clearly erroneous. The applicable statute and regulation are Section 23(a) (1) (A) of the Internal Revenue Code, as amended by Section 121 of the Revenue Act of 1942, c. 619, 56 Stat. 798; and Sec. 29.23 of Treasury Regulations III, promulgated under said code.

Under…

2Cases cited9 opinions

  1. Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  2. Burford-Toothaker Tractor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. Commercial Iron Works v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1948
  4. J. H. Robinson Truck Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
  5. Leedy-Glover Realty & Insurance Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950

4 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  2. Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
  3. Hudlow v. CommissionerUnited States Tax Court · 1971
  4. City Chevrolet Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1956
  5. Alma Piston Co. v. CommissionerUnited States Tax Court · 1976

12 more not listed; retrieve them via the Exa API.

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