Pauli v. Commissioner
United States Board of Tax Appeals
The sum of $6,000 paid to the petitioner in 1919 and 1920, by the partnership of which he was a member, and entered in the firm books as salary, was a distribution of anticipated profits and not compensation for services performed for the partnership as determined by the respondent.
1Opinion of the Court
*785OPINION.
ARundell :
The petitioner contends that the $6,000 paid to him in 1919 and 1920 by the partnership, and entered in its books in an account termed “Salaries-Pártners,” was not in fact compensation for services rendered the firm, but Avas the maximum amount each member was permitted to, and did, clraAV as profits of the partnership in advance of the determination of actual earnings. The respondent, in auditing the returns of the petitioner and the books of the partnership, treated the amount as salary to the former and an expense of the latter, with the result that he determined the…
2Cases cited1 opinion
- Evans v. WarnerAppellate Division of the Supreme Court of the State of New York · 1897
3Cited by6 opinions
- Commissioner of Internal Revenue v. Richard E. And Helen MoranCourt of Appeals for the Eighth Circuit · 1956
- Commissioner of Internal Revenue v. Everett and Mary C. DoakCourt of Appeals for the Fourth Circuit · 1956
- Foster v. United StatesDistrict Court, S.D. New York · 1963
- Commissioner of Internal Revenue v. Everett and Mary C. DoakCourt of Appeals for the Fourth Circuit · 1956
- Goodman v. CommissionerUnited States Tax Court · 1950
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