Legal Opinion

Marra Bros. v. Commissioner

United States Tax Court

Decided December 18, 1944No. Docket No. 2873Unpublished

(1) Petitioner's business for many years has consisted of stevedoring and renting piers for short periods to steamship companies. For the five years, 1936 to 1940, inclusive, its average gross receipts from its business were in excess of $900,000 annually. In 1940 it paid its president, who devoted all of his time to the business and was its chief executive officer, $25,000 for his services. This was the same salary which it had paid him for each of the four preceding years.

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(1) Petitioner's business for many years has consisted of stevedoring and renting piers for short periods to steamship companies. For the five years, 1936 to 1940, inclusive, its average gross receipts from its business were in excess of $900,000 annually. In 1940 it paid its president, who devoted all of his time to the business and was its chief executive officer, $25,000 for his services. This was the same salary which it had paid him for each of the four preceding years. In the same year it paid its vice-president, who devoted his entire time to the business and was next in responsibility…

1Opinion of the Court

Marra Bros., Inc. v. Commissioner.

Marra Bros. v. Commissioner

Docket No. 2873.

United States Tax Court

1944 Tax Ct. Memo LEXIS 7; 3 T.C.M. (CCH) 1317; T.C.M. (RIA) 44404;

December 18, 1944(1) Petitioner's business for many years has consisted of stevedoring and renting piers for short periods to steamship companies. For the five years, 1936 to 1940, inclusive, its average gross receipts from its business were in excess of $900,000 annually. In 1940 it paid its president, who devoted all of his time to the business and was its chief executive officer, $25,000 for his services. This was the same…

2Cases cited2 opinions

  1. Bateman v. CommissionerUnited States Board of Tax Appeals · 1936
  2. Heywood Boot & Shoe Co. v. Commissioner of Internal Rev.Court of Appeals for the First Circuit · 1935

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