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BRINGWALD, INC. v. UNITED STATES

No. 136-61.

334 F.2d 639 (1964)

BRINGWALD, INC. v. The UNITED STATES.

United States Court of Claims.

Rehearing Denied October 16, 1964.

Attorney(s) appearing for the Case

John E. McClure, Washington, D. C., for plaintiff. John P. McClure, Washington, D. C., was on the brief.

Robert Livingston, Washington, D. C., with whom was Asst. Atty. Gen. Louis F. Oberdorfer, for defendant. Edward S. Smith, Lyle M. Turner, Philip R. Miller, and Earl L. Huntington, Washington, D. C., were on the brief.

Before JONES, Senior Judge, WHITAKER, LARAMORE, DURFEE and DAVIS, Judges.

JONES, Senior Judge.1

This is an action to recover $15,729.58 as alleged overpayment of Federal income tax and interest for the years 1953-1955. The principal issue in this case concerns the reasonableness of salaries paid a husband and wife who were the officers and virtually sole stockholders of the corporate taxpayer.

The taxpayer is a small truck-leasing company in Terre Haute, Indiana. At all times material here, it had one...

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