United States v. Philadelphia Knitting Mills Co.
Court of Appeals for the Third Circuit
In Error to the District Court of the United States for the Eastern District of Pennsylvania; Oliver B. Dickinson, Judge.' Suit by the United States against the Philadelphia Knitting Mills Company. Judgment in favor of defendant, 268 Fed. 270, and the United States brings error.
1Opinion of the Court
WOOLLEY, Circuit Judge.
In ascertaining taxable net income under the Corporation Excise Tax Act of August 5, 1909 (36 Stat. 112),. the Philadelphia Knitting Mills Company, in its returns for the years 1909 to 1912, inclusive, deducted from its gross income, as "ordinary and necessary expenses,” salaries paid W. H. Bilyeu, its president, for the year 1909, $12,500, and for each succeeding year, $20,000. Regarding these salaries (in excess of $5,000 per annum) as unreasonable with reference to the services rendered, and therefore not deductible, the Bureau of Internal Revenue demanded payment of…
2Cases cited1 opinion
- Jacobs & Davies, Inc. v. AndersonCourt of Appeals for the Second Circuit · 1915
3Cited by46 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Ox Fibre Brush Co. v. BlairCourt of Appeals for the Fourth Circuit · 1929
- Becker Bros. v. United StatesCourt of Appeals for the Second Circuit · 1925
- Buchman v. American Foam Rubber CorporationDistrict Court, S.D. New York · 1965
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