R. P. FARNSWORTH & CO. v. COMMISSIONER OF INTERNAL REV.

No. 14160.

203 F.2d 490 (1953)

R. P. FARNSWORTH & CO., Inc. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

April 10, 1953.


Attorney(s) appearing for the Case

R. Emmett Kerrigan, Marian Mayer, New Orleans, La., Deutsch, Kerrigan & Stiles, Ralph L. Kaskell, Jr., New Orleans, La., of counsel, for petitioner.

Maryhelen Wigle, Harry Baum, Sp. Assts. to Atty. Gen., Charles S. Lyon, Asst. Atty. Gen., Ellis N. Slack, Acting Asst. Atty. Gen., Charles W. Davis, Chief Counsel, Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, Washington, D. C., for respondent.

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


HOLMES, Circuit Judge.

The question presented is whether salaries paid by petitioner to its seven executive officers, plus contributions made by it to a pension trust fund for the benefit of the same officers, were deductible as reasonable compensation for services rendered the corporation by each of them during the years 1944 and 1945, as contemplated by Section 23(a) (1) (A) and (p) (1) (D) of the Internal Revenue Code, 26 U.S.C.A. § 23 (a) (1) (A), (p) (1...

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