Essellen Realty Corp. v. Commissioner
This text of 12 B.T.A. 739 (Essellen Realty Corp. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
[740]*740OPINION.
The facts are stipulated. The Commissioner made his determination on the theory that since the garage did not start operations until May 12, no salary accrued prior to that date. The stipulation shows that valuable services were rendered to the corporation before the garage was formally opened and that the officers devoted their time to the corporation over the entire year. The petitioner is entitled to deduct the salaries accrued during the year (section 234(a) (1), Revenue Act of 1918) and not merely the amount which accrued after the garage was completed and put into operation.
Decision will be entered under Bule 50.
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Cite This Page — Counsel Stack
12 B.T.A. 739, 1928 BTA LEXIS 3470, Counsel Stack Legal Research, https://law.counselstack.com/opinion/essellen-realty-corp-v-commissioner-bta-1928.