Legal Opinion
Heil Beauty Supplies, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided October 15, 1952No. 14360_1PublishedCited by 67 opinions
1Opinion of the Court
JOHNSEN, Circuit Judge.
A corporate taxpayer seeks review of a decision of the Tax Court, which held that the amounts paid by it as “commission” to one of its officers — the owner of approximately 70 per cent of its capital stock — did not represent “compensation for personal services actually rendered”, but constituted in reality and fact a distribution of corporate profits in lieu of dividends, and that such payments therefore were not deductible, for income tax purposes, as “ordinary and necessary expenses” in carrying on the corporate business, under section 23(a) (1) (A) of the Internal…
2Cases cited7 opinions
- Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
- Carmack Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Twin City Tile & M. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1929
- Ecco High Frequency Corp. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1948
- Gem Jewelry Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
2 more not listed; retrieve them via the Exa API.
3Cited by67 opinions
- W. Horace Williams, Sr., and Viola Bloch Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1957
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1976
- Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
62 more not listed; retrieve them via the Exa API.