United States v. Safety Engineering and Supply Company, Inc.
This text of 374 F.2d 885 (United States v. Safety Engineering and Supply Company, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
The Government appeals from a judgment entered by the District Court after an adequate evidentiary hearing holding that the compensation, including the disputed bonus paid to each of two principal stockholder-officer-employees was reasonable, did not constitute constructive dividends and was therefore properly deductible by the corporate Taxpayer. 26 U.S.C.A. § 162; Treas.Reg. § 1.162-7 (b) (1) and (3) (1954).
We find the appeal and record wholly without any redeeming merit, but since we have expended the travail for submission, we dispose of it on its merits or, more accurately, the lack of them, rather than dismiss as frivolous.
Affirmed.
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374 F.2d 885, 19 A.F.T.R.2d (RIA) 1028, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-safety-engineering-and-supply-company-inc-ca5-1967.