Elbert Steel Corp. v. Commissioner
United States Tax Court
Petitioner, at a time when it was experiencing serious operating losses, entered into an oral contract of employment with one Kitfield whereby it was agreed that if Kitfield would become petitioner's vice president in charge of sales and put the company on a profitable basis of operation, he could have the net profits resulting from the business.
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Petitioner, at a time when it was experiencing serious operating losses, entered into an oral contract of employment with one Kitfield whereby it was agreed that if Kitfield would become petitioner's vice president in charge of sales and put the company on a profitable basis of operation, he could have the net profits resulting from the business. Held, under the facts and circumstances, a salary of $46,000 in a later profitable year was not excessive and was reasonable compensation for services rendered.
1Opinion of the Court
Elbert Steel Corporation v. Commissioner.
Elbert Steel Corp. v. Commissioner
Docket No. 4401.
United States Tax Court
1945 Tax Ct. Memo LEXIS 188; 4 T.C.M. (CCH) 537; T.C.M. (RIA) 45176;
May 21, 1945
Petitioner, at a time when it was experiencing serious operating losses, entered into an oral contract of employment with one Kitfield whereby it was agreed that if Kitfield would become petitioner's vice president in charge of sales and put the company on a profitable basis of operation, he could have the net profits resulting from the business. Held, under the facts and circumstances, a salary of…
2Cases cited3 opinions
- Martin v. New York Life InsuranceNew York Court of Appeals · 1895
- Lonsdale v. J. A. Migel, Inc.Appellate Division of the Supreme Court of the State of New York · 1927
- Gulickson v. Seglin Construction Co., New York County Courts1934