EDWIN'S, INC. v. UNITED STATES

No. 73-1262.

501 F.2d 675 (1974)

EDWIN'S, INC., Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided September 4, 1974.


Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., Michael L. Paup, Atty., Dept. of Justice, Tax Div., Washington, D. C., John O. Olson, U. S. Atty., Madison, Wis., for defendant-appellant.

Samuel Goldenberg, Milwaukee, Wis., for plaintiff-appellee.

Before SWYGERT, Chief Judge, PELL, Circuit Judge, and ESCHBACH, District Judge.


PELL, Circuit Judge.

This is an appeal by the United States of America from the district court's decision that the amount of compensation paid by the taxpayer corporation to certain employees was "reasonable compensation" and, therefore, fully deductible from taxable income.

The taxpayer, Edwin's Incorporated, is a women's specialty store in Eau Claire, Wisconsin. Edwin and Rose Marcus originally purchased the store in 1950 and operated it as a partnership...

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