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INDIALANTIC, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 12120.

216 F.2d 203 (1954)

INDIALANTIC, Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

As Amended November 10, 1954.

Attorney(s) appearing for the Case

B. Dave Bushaw, and Arnold F. Zeleznik, Detroit, Mich., for petitioner.

C. Guy Tadlock, Washington, D. C. (H. Brian Holland, Ellis N. Slack, A. F. Prescott, Washington, D. C., on the brief), for respondent.

Before ALLEN, McALLISTER and MILLER, Circuit Judges.

PER CURIAM.

In its income tax for 1948 petitioner deducted the amount of $50,000 voted to be paid as compensation for legal, presidential and managerial services to Harold H. Emmons, who had been president and director of the company for some thirteen years. The Commissioner disallowed the entire deduction. The Tax Court determined that the reasonable compensation for the thirteen-year period was $32,500. Petitioner had already paid Emmons $15,000 in $5,000 payments...

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