Hoffman Radio Corp. v. Commissioner of Internal Rev.

HEALY, Circuit Judge.

This is a proceeding to review a decision of the Tax Court determining deficiencies in the petitioner’s income and excess profits taxes for the year 1943. Specifically, the grievance urged is the disallowance in part of a deduction taken by petitioner as the salary of its president, M. L. Hoffman, for that year. The deduction claimed was for the sum of $63,613.20, paid Hoffman pursuant to an employment contract entered into in December 1941. The Tax Court on proceedings to redetermine the Commissioner’s deficiency assessment fixed $40,000 as a reasonable deduction for tax…