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ATLANTIC-PACIFIC MANUFACTURING CORP. v. COMMISSIONER

Docket No. 3516.

4 T.C.M. 72 (1945)

Atlantic-Pacific Manufacturing Corp. v. Commissioner.

United States Tax Court.

Entered January 23, 1945.

Attorney(s) appearing for the Case

Frank J. Albus, Esq., for the petitioner. Walt Mandry, Esq., for the respondent.

Memorandum Opinion

STERNHAGEN, Judge:

The disallowance of $18,000 of a deduction of $60,000 taken by the taxpayer for 1941 as compensation for services resulted in the determination of an aggregate deficiency of $8,063.04 in income tax, excess profits tax, and declared value excess profits tax. It was held that the deduction taken exceeded a reasonable allowance for compensation for personal services actually rendered. The taxpayer, recognizing its burden...

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