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CANAL NAVIGATION & TRADING CO., INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 12257.

168 F.2d 512 (1948)

CANAL NAVIGATION & TRADING CO., Inc. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

Rehearing Denied July 30, 1948.

Attorney(s) appearing for the Case

Joseph M. Jones, of New Orleans, La., for petitioner.

Homer R. Miller, Robert N. Anderson and Louise Foster, Sp. Assts. to the Atty. Gen., Theron L. Caudle, Asst. Atty. Gen., and Charles Oliphant, Chief Counsel, Bureau of Internal Revenue, and Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before HUTCHESON, HOLMES, and McCORD, Circuit Judges.

PER CURIAM.

For the period from May 17, 1941 to December 31, 1941, taxpayer paid to three of its officers salaries aggregating $10,000, — to its president, Joseph M. Jones, and its vice-president, Thomas L. Jordan, $4,286 each, and to its vice-president, Harry B. Jordan, $1,428. The commissioner approving a total allowance for salaries for these officers of $4,500, disallowed $5,500 with resulting deficiencies in income and excess profits tax liabilities for...

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