Fifth Ave. Coach Lines,Inc. v. Commissioner
United States Tax Court
1. Petitioner's past president had served petitioner for many years and during a period of severe difficulties, when the petitioner attempted to acquire bus franchises, without a salary increase. He played a prominent role in securing bus franchises for petitioner; the petitioner's bus operation resulted in large profits for the petitioner, which had been suffering heavy losses for years. Thereafter, the president received a substantial wage increase.
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1. Petitioner's past president had served petitioner for many years and during a period of severe difficulties, when the petitioner attempted to acquire bus franchises, without a salary increase. He played a prominent role in securing bus franchises for petitioner; the petitioner's bus operation resulted in large profits for the petitioner, which had been suffering heavy losses for years. Thereafter, the president received a substantial wage increase. Neither the president nor his wife owned any of petitioner's stock. Held, payments by the petitioner to its past president's widow equal in…
1Opinion of the Court
Train, Judge:
The respondent determined deficiencies in the petitioner’s income and excess profits taxes for the years and in the amounts as follows:
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The issues to be decided are:(1) Whether the petitioner is entitled to deductions for the taxable years 1944 through 1948 for payments made to the widow of a deceased former officer, in the amount of $7,500 per annum, as further compensation for past services rendered by that official;(2) Whether petitioner is entitled to deduct in 1946 and 1948 wages for services rendered by employees in those years in the amounts of $83,226.52 and…
2Cases cited41 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. SunnenSupreme Court of the United States · 1948
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
36 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Home Interiors & Gifts, Inc. v. CommissionerUnited States Tax Court · 1980
- Commissioner of Internal Revenue v. Fifth Avenue Coach Lines, Inc., Fifth Avenue Coach Lines, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Barbourville Brick Co. v. CommissionerUnited States Tax Court · 1961
- Evans v. CommissionerUnited States Tax Court · 1962
- Schner-Block Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
34 more not listed; retrieve them via the Exa API.