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BARTON-GILLET COMPANY v. COMMISSIONER OF INTERNAL REVENUE

No. 15293.

442 F.2d 1343 (1971)

The BARTON-GILLET COMPANY, a corporation, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 11, 1971.

Attorney(s) appearing for the Case

Charles G. Page, Baltimore, Md. (White, Page & Lentz, Baltimore, Md., on brief), for appellant.

Richard Halberstein, Atty., Tax Div., Dept. of Justice (Johnnie M. Walter, Asst. Atty. Gen., Meyer Rothwacks, Leonard J. Henzke, Jr., Attys., Tax Div., Dept. of Justice, on brief), for appellee.

Before BOREMAN, BRYAN and CRAVEN, Circuit Judges.

PER CURIAM:

This is an income tax case. The Commissioner determined deficiencies in the corporation income tax of the petitioner for the taxable years ended December 31, 1964, 1965 and 1966. The Commissioner determined that certain amounts paid (commissions, salaries and contributions to a qualified profit sharing trust) by petitioner to its chief executive officer, and claimed to be fully deductible for income tax purposes as a trade or business expense, were unreasonable...

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