Manu-Mine Research & Development Co. v. Commissioner
United States Tax Court
1. Respondent has failed to prove fraud for the taxable years here involved. 2. Reasonable compensation of three officers of petitioner determined from the evidence. 3. Two officers of petitioner (husband and wife) and their four children and a governess took an 8 or 9-day trip to Hawaii in the taxable year ended October 31, 1955, at a cost of approximately $8,000. Petitioner had a branch office in Hawaii.
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1. Respondent has failed to prove fraud for the taxable years here involved. 2. Reasonable compensation of three officers of petitioner determined from the evidence. 3. Two officers of petitioner (husband and wife) and their four children and a governess took an 8 or 9-day trip to Hawaii in the taxable year ended October 31, 1955, at a cost of approximately $8,000. Petitioner had a branch office in Hawaii. Held, $3,000 of the cost of the trip represented a business expense of the petitioner. 4. Compensation paid for services actually rendered by two persons during 3 months of the taxable year…
1Opinion of the Court
Manu-Mine Research and Development Company v. Commissioner.
Manu-Mine Research & Development Co. v. Commissioner
Docket No. 2732-62.
United States Tax Court
T.C. Memo 1967-244; 1967 Tax Ct. Memo LEXIS 18; 26 T.C.M. (CCH) 1259; T.C.M. (RIA) 67244;
December 7, 1967
1. Respondent has failed to prove fraud for the taxable years here involved.
2. Reasonable compensation of three officers of petitioner determined from the evidence.
3. Two officers of petitioner (husband and wife) and their four children and a governess took an 8 or 9-day trip to Hawaii in the taxable year ended October 31, 1955, at a cost…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Commissioner v. TellierSupreme Court of the United States · 1966
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
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3Cited by3 opinions
- United States v. John William Gotcher Et Ux.Court of Appeals for the Fifth Circuit · 1968
- Charles W. Stickler, Jr., and Nellie M. L. Stickler v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1972
- United States v. John William Gotcher Et Ux.Court of Appeals for the Fifth Circuit · 1968