Thomas P. Byrnes, Inc. v. Commissioner
United States Tax Court
Petitioner received sales commissions pursuant to several sales representation agreements. Although the commissions were obtained as a result of the sales efforts of petitioner's president, who, in addition, was its primary shareholder and principal employee, the agreements neither named nor described him individually. Held, the commissions were not personal holding company income under sec. 543(a)(7), I.R.C. 1954.
1Opinion of the Court
Thomas P. Byrnes, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Thomas P. Byrnes, Inc. v. Commissioner
Docket No. 8679-78
United States Tax Court
73 T.C. 416; 1979 U.S. Tax Ct. LEXIS 10;
December 4, 1979, Filed
Decision will be entered for the petitioner.
Petitioner received sales commissions pursuant to several sales representation agreements. Although the commissions were obtained as a result of the sales efforts of petitioner's president, who, in addition, was its primary shareholder and principal employee, the agreements neither named nor described him individually. Held, the…
2Cases cited6 opinions
- Kurt Frings Agency, Inc. v. CommissionerUnited States Tax Court · 1964
- General Management Corp. v. COM'R OF INT. REVENUECourt of Appeals for the Seventh Circuit · 1943
- Able Metal Products, Inc. v. CommissionerUnited States Tax Court · 1959
- Allen Machinery Corp. v. CommissionerUnited States Tax Court · 1958
- Claggett v. CommissionerUnited States Tax Court · 1965
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