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ALGER-SULLIVAN LUMBER CO. v. COMMISSIONER OF INT. REV.

No. 6197.

57 F.2d 3 (1932)

ALGER-SULLIVAN LUMBER CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied May 3, 1932.

Attorney(s) appearing for the Case

W. W. Spalding, of Washington, D. C., for petitioner.

G. A. Youngquist, Asst. Atty. Gen., Sewall Key, A. G. Divet, and J. Louis Monarch, Sp. Assts. to the Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and De Witt M. Evans, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before BRYAN, FOSTER, and WALKER, Circuit Judges.

FOSTER, Circuit Judge.

Pursuant to written agreements, in 1921 petitioner transferred on its books and delivered 150 shares of its capital stock, having a market value of $18,375.00, to four of its employees. Treating these transactions as the payment of bonuses as reasonable and extra compensation for services rendered by the said employees, petitioner deducted the amount as an expense of doing business. The Commissioner ruled against this contention, and held that...

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