King, Quirk & Co. v. Commissioner
United States Tax Court
1. Bonuses paid to petitioner's three officer-stockholders in 1955, when added to their fixed salaries for that year, did not constitute unreasonable compensation for services rendered. 2. Fixed annual salary of petitioner's secretary-treasurer was not unreasonable compensation for the service he rendered. 3. Petitioner's secretary-treasurer did not own more than 50 percent in value of petitioner's stock in 1952 and 1953, and section 24(c), I.R.C. 1939, does not prevent the…
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1. Bonuses paid to petitioner's three officer-stockholders in 1955, when added to their fixed salaries for that year, did not constitute unreasonable compensation for services rendered. 2. Fixed annual salary of petitioner's secretary-treasurer was not unreasonable compensation for the service he rendered. 3. Petitioner's secretary-treasurer did not own more than 50 percent in value of petitioner's stock in 1952 and 1953, and section 24(c), I.R.C. 1939, does not prevent the deduction of that officer's full salary accrued in those years but not paid until May 1954. 4. Petitioner has failed to…
1Opinion of the Court
King, Quirk & Co., Inc. v. Commissioner.
King, Quirk & Co. v. Commissioner
Docket No. 72395.
United States Tax Court
T.C. Memo 1961-274; 1961 Tax Ct. Memo LEXIS 75; 20 T.C.M. (CCH) 1429; T.C.M. (RIA) 61274;
September 29, 1961
1. Bonuses paid to petitioner's three officer-stockholders in 1955, when added to their fixed salaries for that year, did not constitute unreasonable compensation for services rendered.
2. Fixed annual salary of petitioner's secretary-treasurer was not unreasonable compensation for the service he rendered.
3. Petitioner's secretary-treasurer did not own more than 50 percent in…
2Cases cited38 opinions
- L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Sutter v. CommissionerUnited States Tax Court · 1953
- Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
- Miles-Conley Co. v. CommissionerUnited States Tax Court · 1948
- Wilson v. CommissionerUnited States Tax Court · 1948
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