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SEVEN CANAL PLACE CORPORATION v. C. I. R.

No. 397, Docket 28323.

332 F.2d 899 (1964)

SEVEN CANAL PLACE CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 26, 1964.

Attorney(s) appearing for the Case

Casey, Lane & Mittendorf, New York City (Robert Beshar, New York City, of counsel), for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen. (Lee A. Jackson, Robert H. Anderson and Donald W. Williamson, Jr., Attys., Dept. of Justice), Washington, D. C., for respondent.

Before SWAN, MOORE and SMITH, Circuit Judges.

MOORE, Circuit Judge.

Petitioner, Seven Canal Place Corporation, appeals from a decision of the Tax Court which allowed petitioner $5,200 as a deduction for all officers' salaries for the tax year 1955 instead of $9,400 claimed in petitioner's 1955 return. As a result, a deficiency of $2,370 in tax was asserted by respondent.

For some years prior to 1955, petitioner owned two parcels of real property in the Bronx...

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