Great Island Holding Corp. v. Commissioner
United States Tax Court
1. Petitioner, the Great Island Holding Corporation, and several related corporations had the same officers and offices and had, to some extent, the same employees. The respondent disallowed all except $ 5,000 of the sum of $ 94,091.34 paid by petitioner as salaries and compensation during the taxable year.
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1. Petitioner, the Great Island Holding Corporation, and several related corporations had the same officers and offices and had, to some extent, the same employees. The respondent disallowed all except $ 5,000 of the sum of $ 94,091.34 paid by petitioner as salaries and compensation during the taxable year. Held, the amount paid and deducted by petitioner, less the sum of $ 14,500 represented by specific adjustments made herein, is deductible by petitioner. 2. Petitioner is not entitled to deduct franchise taxes and interest thereon in the taxable year where it did not accrue such taxes and…
1Opinion of the Court
Aettndell, Judge:
The respondent has determined deficiencies in income tax and personal holding company surtax against petitioners, as follows:
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The cases were consolidated for trial.
The issues presented in the case of the Great Island Holding Corporation are (1) whether a reasonable allowance for salaries of officers and employees exceeds $5,000; (2) (a) whether New York franchise tax accrued on November 1, 1937, so that the amount thereof is deductible in the taxable year; and (b) whether a deduction is allowable for interest paid for the taxable year on the New York franchise…
2Cases cited5 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Longhorn Portland Cement Co. v. CommissionerUnited States Tax Court · 1944
3Cited by61 opinions
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
- Baltimore Transfer Co. v. CommissionerUnited States Tax Court · 1947
- Stamos v. CommissionerUnited States Tax Court · 1954
- Standard Paving Co. v. CommissionerUnited States Tax Court · 1949
- Lehigh v. R. Co. v. CommissionerUnited States Tax Court · 1949
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