Platt Trailer Co. v. Commissioner
United States Tax Court
1. Held, petitioner failed to prove that amounts in excess of $ 500 paid to its vice president were reasonable compensation for personal services actually rendered within the purview of section 23 (a) of the 1939 Code. 2. Salaries payable to petitioner's president and secretary-treasurer were accrued on petitioner's books and were included in the officers' gross income.
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1. Held, petitioner failed to prove that amounts in excess of $ 500 paid to its vice president were reasonable compensation for personal services actually rendered within the purview of section 23 (a) of the 1939 Code. 2. Salaries payable to petitioner's president and secretary-treasurer were accrued on petitioner's books and were included in the officers' gross income. Held, the salaries were constructively received and their deduction was not barred by section 24 (c) of the 1939 Code. 3. The Commissioner disallowed the deduction of an $ 1,800 addition to petitioner's bad debt reserve in…
1Opinion of the Court
OPINION.
BRUCE, Judge:
Respondent determined deficiencies in the tax of the petitioner and an addition to tax, as follows:
1944.. 1945.. 1946-Income tax deficiency $3,165.83 1,275.37 16,289.17 Declared value excess-profits tax deficiency $1,338.48 Excess profits tax deficiency $2,065.56 12,684.11 Addition to tax-sec. 291 (a) $516.38
The issues for decision are whether the Commissioner correctly determined that all of the accrued salaries of petitioner’s vice president in excess of $500 were not allowable deductions under section 23 (a) of the 1939 Code, that the deduction of accrued but unpaid…
2Cases cited14 opinions
- Reinecke v. SpaldingSupreme Court of the United States · 1930
- Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
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- Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
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