Legal Opinion
Indialantic, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided November 10, 1954No. 12120PublishedCited by 3 opinions
1Per curiam
In its income tax for 1948 petitioner deducted the amount of $50,000 voted to be paid as compensation for legal, presidential and managerial services to Harold H. Emmons, who had been president and director of the company for some thirteen years. The Commissioner disallowed the entire deduction. The Tax Court determined that the reasonable compensation for the thirteen-year period was $32,500. Petitioner had already paid Emmons $15,000 in $5,000 payments made in 1944, 1945, and 1947 and the Tax Court therefore permitted the deduction in 1948 of $17,500.
The facts are not in controversy. In…
2Cases cited7 opinions
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Ox Fibre Brush Co. v. BlairCourt of Appeals for the Fourth Circuit · 1929
- Capitol-Barg Dry Cleaning Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Loesch & Green Const. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
- Toledo Grain & Milling Co. v. Commissioner of Int. Rev.Court of Appeals for the Sixth Circuit · 1932
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3Cited by3 opinions
- Robert Louis Stevenson Apartments, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- J. E. Craig Finance Co. v. United StatesDistrict Court, W.D. South Carolina · 1962
- Auburn & Associates, Inc. v. United StatesDistrict Court, W.D. Pennsylvania · 1971