Rand v. Commissioner
United States Tax Court
During the taxable year 1953 petitioner paid to an officer of a corporation in which petitioner was a stockholder and creditor an amount of $ 8,890.50, which payment was intended as additional compensation to the officer for his services as president of the corporation.
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During the taxable year 1953 petitioner paid to an officer of a corporation in which petitioner was a stockholder and creditor an amount of $ 8,890.50, which payment was intended as additional compensation to the officer for his services as president of the corporation. Held, petitioner is not entitled to any deduction from gross income by reason of such payment, either as a trade or business expense under section 23(a)(1) or as a nontrade or nonbusiness expense under section 23(a)(2), I.R.C. 1939, as amended.
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent determined a deficiency in income tax for the taxable year ended December 31, 1953, in the amount of $3,002.74.
^ CO The only error assigned is “The Commissioner erred in disallowing deduction of $8,890.50 as ‘fees’ paid by petitioner Bert B. Rand to . A. Carraway.”
The facts were all stipulated and are incorporated herein by this reference.
Petitioners are husband and wife and during the year 1953 were residents of the District of Columbia. They filed a joint Federal income tax return for 1953 with the district director of internal revenue at Baltimore,…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Snow v. CommissionerUnited States Tax Court · 1958
- Kaplan v. CommissionerUnited States Tax Court · 1953
- Dinardo v. CommissionerUnited States Tax Court · 1954
- Chick v. CommissionerUnited States Tax Court · 1946
5 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Gould v. CommissionerUnited States Tax Court · 1975
- Hewett v. CommissionerUnited States Tax Court · 1967
- R. Walter Graham and Dorothy H. Graham v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1964
- Picker v. United StatesUnited States Court of Claims · 1967
22 more not listed; retrieve them via the Exa API.