Legal Opinion

Brandtjen & Kluge, Inc. v. Commissioner

United States Tax Court

Decided June 7, 1960No. Docket No. 66583Published

1. Held: On the facts, that the salary paid by petitioner to Henry A. Brandtjen, Jr., in the years 1953, 1954, and 1955 was in excess of a reasonable allowance for salary or compensation for the personal services actually rendered by him.

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1. Held: On the facts, that the salary paid by petitioner to Henry A. Brandtjen, Jr., in the years 1953, 1954, and 1955 was in excess of a reasonable allowance for salary or compensation for the personal services actually rendered by him. The amount representing such reasonable amount determined. 2. Petitioner in 1954 and 1955 concluded that its accounts receivable from its Canadian subsidiary were partially worthless and took steps which were designed and intended to charge off on its books worthless portions of such indebtedness. Held, that the entries made on its books with respect to such…

1Opinion of the Court

Brandtjen & Kluge, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Brandtjen & Kluge, Inc. v. Commissioner

Docket No. 66583

United States Tax Court

34 T.C. 416; 1960 U.S. Tax Ct. LEXIS 136;

June 7, 1960, Filed

Decision will be entered under Rule 50.

1. Held: On the facts, that the salary paid by petitioner to Henry A. Brandtjen, Jr., in the years 1953, 1954, and 1955 was in excess of a reasonable allowance for salary or compensation for the personal services actually rendered by him. The amount representing such reasonable amount determined.

2. Petitioner in 1954 and 1955 concluded…

2Cases cited7 opinions

  1. Poe v. SeabornSupreme Court of the United States · 1930
  2. Wilbur Sec. Co. v. CommissionerUnited States Tax Court · 1959
  3. Berkshire Oil Co. v. CommissionerUnited States Tax Court · 1947
  4. Hamlen v. WelchCourt of Appeals for the First Circuit · 1940
  5. Nippert v. CommissionerUnited States Board of Tax Appeals · 1935

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