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UNIVERSITY CHEVROLET CO. v. COMMISSIONER OF INT. REV.

No. 13997.

199 F.2d 629 (1952)

UNIVERSITY CHEVROLET CO., Inc. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

Rehearing Denied December 17, 1952.

Attorney(s) appearing for the Case

Jas. P. Hill, Jacksonville, Fla., Frederic D. Dassori, Washington, D. C., William R. Frazier, Jacksonville, Fla., for petitioner.

William L. Norton, Jr., Special Asst. to Atty. Gen., A. F. Prescott, Special Asst. Atty. Gen., Ellis N. Slack, Acting Asst. Atty. Gen., Mason B. Leming, Act. Chief Counsel, Bur. Int. Rev., Rollin H. Transue, Special Atty. Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and HOLMES and RUSSELL, Circuit Judges.

HOLMES, Circuit Judge.

This appeal involves income taxes for the year 1946, and is taken from a decision of the Tax Court entered June 29, 1951. 16 T.C. 1452. The question presented is whether said court's findings of reasonable allowances for compensation for personal services for the taxpayer's president and sole stockholder are clearly erroneous. The applicable statute and regulation are Section 23(a) (1) (A) of the Internal Revenue...

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