Thompson-Hayward Chemical Co. v. Commissioner
United States Tax Court
Held, that the deduction for officers' compensation by petitioner in the fiscal year ending January 31, 1947, constituted a class of deductions for that year which exceeded 115 per cent of the average amount of deductions of such class for the 4 previous taxable years and that petitioner, having met its burden of proof under section 433 (b) (10) (C), is entitled to have such excess disallowed in computing its average base period net income.
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Held, that the deduction for officers' compensation by petitioner in the fiscal year ending January 31, 1947, constituted a class of deductions for that year which exceeded 115 per cent of the average amount of deductions of such class for the 4 previous taxable years and that petitioner, having met its burden of proof under section 433 (b) (10) (C), is entitled to have such excess disallowed in computing its average base period net income. Held, further, that the adjustment provisions of section 452, which require an adjustment where a position is taken in the determination of excess profits…
1Opinion of the Court
Thompson-Hayward Chemical Company, a corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Thompson-Hayward Chemical Co. v. Commissioner
Docket No. 64268
United States Tax Court
30 T.C. 96; 1958 U.S. Tax Ct. LEXIS 209;
April 23, 1958, Filed
Decision will be entered under Rule 50.
Held, that the deduction for officers' compensation by petitioner in the fiscal year ending January 31, 1947, constituted a class of deductions for that year which exceeded 115 per cent of the average amount of deductions of such class for the 4 previous taxable years and that petitioner, having met its…
2Cases cited5 opinions
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- Mine & Smelter Supply Co. v. CommissionerUnited States Tax Court · 1948
- McKay Machine Co. v. CommissionerUnited States Tax Court · 1957
- National Biscuit Co. v. CommissionerUnited States Tax Court · 1957
- Thompson-Hayward Chemical Co. v. CommissionerUnited States Tax Court · 1958