Kay, Inc. v. Commissioner
United States Tax Court
Upon the facts, held, (1) respondent improperly disallowed part of the compensation petitioner paid two of its officers during fiscal years 1944, 1945 and 1946; (2) bonuses of the two officers in the fiscal year 1944 constituted additional compensation; (3) the full amount of the bonus accrued by petitioner to one of its officers in the fiscal year 1944 was deductible in the absence of proof that part of it came within the terms of section 24 (c) of the Internal Revenue…
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Upon the facts, held, (1) respondent improperly disallowed part of the compensation petitioner paid two of its officers during fiscal years 1944, 1945 and 1946; (2) bonuses of the two officers in the fiscal year 1944 constituted additional compensation; (3) the full amount of the bonus accrued by petitioner to one of its officers in the fiscal year 1944 was deductible in the absence of proof that part of it came within the terms of section 24 (c) of the Internal Revenue Code; (4) petitioner is entitled to a net operating loss carry-back from the fiscal year 1946 to the fiscal year 1944.
1Opinion of the Court
Kay, Inc. v. Commissioner.
Kay, Inc. v. Commissioner
Docket No. 16437.
United States Tax Court
1949 Tax Ct. Memo LEXIS 54; 8 T.C.M. (CCH) 911; T.C.M. (RIA) 49246;
October 10, 1949
Upon the facts, held, (1) respondent improperly disallowed part of the compensation petitioner paid two of its officers during fiscal years 1944, 1945 and 1946; (2) bonuses of the two officers in the fiscal year 1944 constituted additional compensation; (3) the full amount of the bonus accrued by petitioner to one of its officers in the fiscal year 1944 was deductible in the absence of proof that part of it came within…
2Cases cited1 opinion
- New York Talking Machine Co. v. CommissionerUnited States Board of Tax Appeals · 1928