Heron Metal Bed Co. v. Commissioner

APPEAL OF HERON METAL BED CO.

Heron Metal Bed Co. v. Commissioner

Docket No. 3236.

United States Board of Tax Appeals

2 B.T.A. 305; 1925 BTA LEXIS 2452;

July 11, 1925, Decided Submitted June 18, 1925.

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John S. Fletcher, Esq., for the taxpayer.

R. P. Smith, Esq., for the Commissioner.

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Before STERNHAGEN, LANSDON, and LOVE.

The taxpayer appeals from a determination of a deficiency in income and profits tax of $4,140 for the calendar year 1919, resulting from the disallowance of a deduction for salary of its president.

FINDINGS OF FACT.

During the calendar year 1919 the taxpayer paid its president a salary of $9,000. The president performed substantial service during that year, the directors considered that such services were worth $9,000 in that year, and by a resolution duly adopted such salary was authorized. The Commissioner disallowed the deduction. The salary was reasonable.

DECISION.

The deficiency determined by the Commissioner is disallowed.