HOFFMAN RADIO CORP. v. COMMISSIONER OF INTERNAL REV.

No. 12144.

177 F.2d 264 (1949)

HOFFMAN RADIO CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Ninth Circuit.

October 20, 1949.


Attorney(s) appearing for the Case

Claude I. Parker, John B. Milliken, Ralph Kohlmeier, Harrison Harkins, Los Angeles, Cal. (L. A. Luce, Washington, D.C., of counsel), for petitioner.

Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott and Edward J. P. Zimmerman, Sp. Assts. to Atty. Gen., for respondent.

Before HEALY and BONE, Circuit Judges, and DRIVER, District Judge.


HEALY, Circuit Judge.

This is a proceeding to review a decision of the Tax Court determining deficiencies in the petitioner's income and excess profits taxes for the year 1943. Specifically, the grievance urged is the disallowance in part of a deduction taken by petitioner as the salary of its president, M. L. Hoffman, for that year. The deduction claimed was for the sum of $63,613,20, paid Hoffman pursuant to an employment contract entered into in December 1941....

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