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CITY CHEVROLET COMPANY v. COMMISSIONER OF INTERNAL REVENUE

No. 7023.

228 F.2d 894 (1956)

CITY CHEVROLET COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 11, 1956.

Attorney(s) appearing for the Case

Frederic D. Dassori, Washington, D. C. (Dee R. Bramwell, Washington, D. C., on brief), for petitioner.

C. Guy Tadlock, Atty., Dept. of Justice, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Robert N. Anderson and A. F. Prescott, Attys., Dept. of Justice, Washington, D. C., on brief), for respondent.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.

PER CURIAM.

This is a petition to review a decision of the Tax Court relating to deductions for the year 1946 on account of personal services rendered taxpayer corporation by officers who with their wives were its sole stockholders. The facts are fully stated in the opinion of the Tax Court and need not be repeated here. Taxpayer contends that the bonus of $30,881.69 paid to each of the officers for the year 1946 in addition to salaries of $12,000 each was reasonable...

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