The Barton-Gillet Company, a Corporation v. Commissioner of Internal Revenue

Fourth Circuit

The Barton-Gillet Company, a Corporation v. Commissioner of Internal Revenue

442 F.2d 1343, 27 A.F.T.R.2d (RIA) 1550, 1971 U.S. App. LEXIS 9637

CourtCourt of Appeals for the Fourth Circuit

DecidedJune 11, 1971

Docket15293_1

StatusPublished

Cited by11 cases

This text of 442 F.2d 1343 (The Barton-Gillet Company, a Corporation v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Barton-Gillet Company, a Corporation v. Commissioner of Internal Revenue, 442 F.2d 1343, 27 A.F.T.R.2d (RIA) 1550, 1971 U.S. App. LEXIS 9637 (4th Cir. 1971).

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Opinion

PER CURIAM:

This is an income tax case. The Commissioner determined deficiencies in the corporation income tax of the petitioner for the taxable years ended December 31, 1964, 1965 and 1966. The Commissioner determined that certain amounts paid (commissions, salaries and contributions to a qualified profit sharing trust) by petitioner to its chief executive officer, and claimed to be fully deductible for income tax purposes as a trade or business expense, were unreasonable and excessive within the meaning of Internal Revenue Code of 1954, Sec. 162(a) (1) and the pertinent regulations.

The sole question on appeal is whether the Tax Court was correct in finding that the total compensation paid by the taxpayer corporation to its chief executive officer for the years in question was excessive and unreasonable and that such amounts were therefore not fully deductible.

Upon consideration of the briefs, records, joint appendix and argument of counsel we affirm on the findings and opinion of the Tax Court. 1

1

. T.C.Memo.1970-157, 29 T.C.M. 679.

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PER CURIAM:

This is an income tax case. The Commissioner determined deficiencies in the corporation income tax of the petitioner for the taxable years ended December 31, 1964, 1965 and 1966. The Commissioner determined that certain amounts paid (commissions, salaries and contributions to a qualified profit sharing trust) by petitioner to its chief executive officer, and claimed to be fully deductible for income tax purposes as a trade or business expense, were unreasonable and excessive within the meaning of Internal Revenue Code of 1954, Sec. 162(a) (1) and the pertinent regulations.

The sole question on appeal is whether the Tax Court was correct in finding that the total compensation paid by the taxpayer corporation to its chief executive officer for the years in question was excessive and unreasonable and that such amounts were therefore not fully deductible.

Upon consideration of the briefs, records, joint appendix and argument of counsel we affirm on the findings and opinion of the Tax Court. 1

1

. T.C.Memo.1970-157, 29 T.C.M. 679.

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442 F.2d 1343, 27 A.F.T.R.2d (RIA) 1550, 1971 U.S. App. LEXIS 9637, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-barton-gillet-company-a-corporation-v-commissioner-of-internal-ca4-1971.

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