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UNIVERSITY CHEVROLET COMPANY, INC. v. COMMISSIONER

Docket No. 27672.

16 T.C. 1452 (1951)

UNIVERSITY CHEVROLET COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 29, 1951.

Attorney(s) appearing for the Case

Frederic D. Dassori, Esq., for the petitioner.

William W. Oliver, Esq., and Ralph B. Bradbury, Esq., for the respondent.

The Commissioner determined a deficiency of $6,896.61 in the income tax of the petitioner for 1946. The issue for decision is whether the Commissioner erred in holding that a reasonable allowance for 1946 as compensation for personal services rendered to the petitioner by Latham Davis, as its president, was only $14,643.24 of the $27,655.73 claimed on the return.

FINDINGS OF FACT.

The corporation income tax return of the petitioner for 1946 was filed with...

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