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LEEDY-GLOVER RLTY. & INS. CO. v. COMMISSIONER OF INT. R.

No. 13234.

184 F.2d 833 (1950)

LEEDY-GLOVER REALTY & INSURANCE CO., Inc. et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

Rehearing Denied December 15, 1950.

Attorney(s) appearing for the Case

Benjamin Leader, Alfred Swedlaw, Birmingham, Ala., for petitioners.

Hilbert P. Zarky, Ellis N. Slack, Robert N. Anderson, Morton K. Rothschild, Special Assistants to Attorney General, Theron Lamar Caudle, Assistant Attorney General, Charles Oliphant, Chief Counsel, W. Herman Schwatka, Special Attorney, Bureau of Internal Revenue, Washington, D. C., for respondent.

Before McCORD, BORAH and RUSSELL, Circuit Judges.

PER CURIAM.

This Court has held that the question of what constitutes a reasonable allowance for salary expense under the provisions of Section 23(a) (1) (A) of the Internal Revenue Code and the applicable treasury regulations is a question of fact under the circumstances of each particular case. See Gem Jewelry Co. v. Commissioner, 5 Cir., 165 F.2d 991; Commercial Iron Works v. Commissioner, 5 Cir., 166 F.2d 221<...

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