Nicholas Co. v. Commissioner
United States Tax Court
1. Amounts treated by petitioner as "salary" to its president, who performed little or no services, held, in the circumstances, to represent part of the purchase price of assets of the going business of a predecessor proprietorship which had theretofore been operated by said president; and that said amounts are not deductible as current operating expenses. 2. Amounts paid by petitioner to or at the direction of said proprietor, and claimed by it to represent the expense of…
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1. Amounts treated by petitioner as "salary" to its president, who performed little or no services, held, in the circumstances, to represent part of the purchase price of assets of the going business of a predecessor proprietorship which had theretofore been operated by said president; and that said amounts are not deductible as current operating expenses. 2. Amounts paid by petitioner to or at the direction of said proprietor, and claimed by it to represent the expense of "leasing" assertedly unassignable intangible assets of the proprietorship, held, also to be part of the purchase price of…
1Opinion of the Court
The Nicholas Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Nicholas Co. v. Commissioner
Docket No. 83726
United States Tax Court
38 T.C. 348; 1962 U.S. Tax Ct. LEXIS 124;
June 18, 1962, Filed
Decision will be entered for the respondent.
1. Amounts treated by petitioner as "salary" to its president, who performed little or no services, held, in the circumstances, to represent part of the purchase price of assets of the going business of a predecessor proprietorship which had theretofore been operated by said president; and that said amounts are not deductible as current…
2Cases cited1 opinion
- Nicholas Co. v. CommissionerUnited States Tax Court · 1962