American Allsafe Co. v. Commissioner
United States Tax Court
Petitioner is a corporation engaged in the manufacture and sale of safety equipment. Its four corporate officers were its sole directors and, with their wives, its only stockholders. Under a management agreement, compensation paid its four officers was contingent upon net profits. The growth and success of the corporation were largely due to the efforts of two of its officers, who as co-managers had complete charge and supervision of its business.
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Petitioner is a corporation engaged in the manufacture and sale of safety equipment. Its four corporate officers were its sole directors and, with their wives, its only stockholders. Under a management agreement, compensation paid its four officers was contingent upon net profits. The growth and success of the corporation were largely due to the efforts of two of its officers, who as co-managers had complete charge and supervision of its business. Held, on the facts, that a portion of the compensation paid petitioner's president during each of the taxable years involved, was excessive and not…
1Opinion of the Court
American Allsafe Company, Inc. v. Commissioner.
American Allsafe Co. v. Commissioner
Docket No. 36407.
United States Tax Court
1954 Tax Ct. Memo LEXIS 318; 13 T.C.M. (CCH) 95; T.C.M. (RIA) 54033;
January 29, 1954
Petitioner is a corporation engaged in the manufacture and sale of safety equipment. Its four corporate officers were its sole directors and, with their wives, its only stockholders. Under a management agreement, compensation paid its four officers was contingent upon net profits. The growth and success of the corporation were largely due to the efforts of two of its officers, who as…
2Cases cited3 opinions
- Long Island Drug Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Kerrigan Iron Works, Inc. v. CommissionerUnited States Tax Court · 1951
- D. & N. Auto Parts Co. v. CommissionerUnited States Tax Court · 1947