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SAVKO BROTHERS COMPANY v. C. I. R.

No. 15742.

338 F.2d 956 (1964)

SAVKO BROTHERS COMPANY, an Ohio Corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

November 17, 1964.

Attorney(s) appearing for the Case

Argued by C. Stanley Taylor, Columbus, Ohio, Schwenker, Teaford, Brothers & Bernard, Columbus, Ohio, on the brief, Robert E. Teaford, Columbus, Ohio, of counsel, for petitioner.

Argued by Carolyn R. Just, Dept. of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz and Carolyn R. Just, Attys., Dept. of Justice, Washington, D. C., on the brief, for respondent.

Before EDWARDS, Circuit Judge, BOYD, District Judge, and PRETTYMAN, Senior Circuit Judge.

PER CURIAM.

In this appeal the taxpayer (Savko Brothers Company) seeks to reverse a tax deficiency judgment of $4,096.79. The Commissioner had previously found (and had contended before the Tax Court for) a deficiency of $36,496.51. The dispute turns upon whether or not salaries and bonuses paid to the corporation's two principal officers and stockholders were or were not "reasonable" within the meaning of Internal Revenue...

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