Hudson Motor Car Co. v. United States

WHALEY, Judge.

The question presented in this case is whether plaintiff is entitled to deductions from gross income in the fiscal year ended November 30, 1919, on account of certain treasury stock which was delivered to three of its employees under contracts relating to their employment by plaintiff. The primary question is whether the stock was delivered to the employees in 1919 as compensation for services rendered in that year and therefore would constitute an allowable deduction in that year or whether the stock was being purchased by the employees through the application of dividends to…