HAROLDS CLUB v. C. I. R.

No. 19265.

340 F.2d 861 (1965)

HAROLDS CLUB, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

January 19, 1965.


Attorney(s) appearing for the Case

Kent & Brookes, and Valentine Brookes, San Francisco, Cal., for petitioner.

John B. Jones, Acting Asst. Atty. Gen., Lee A. Jackson, David O. Walter, and William A. Friedlander, Attys., Dept. of Justice, Tax Division, Washington, D. C., for respondent.

Before POPE, HAMLEY and KOELSCH, Circuit Judges.


HAMLEY, Circuit Judge.

This petition to review a decision of the Tax Court brings into question business expense deductions of Harolds Club, a Nevada corporation, claimed in its federal income tax returns for the years 1952 to 1956.

In those years Harolds Club paid Raymond I. Smith (Smith) an annual salary of ten thousand dollars plus twenty percent of the net profits of the company for each of the years in question. The salaries so computed ranged in amount...

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