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NOR-CAL ADJUSTERS v. C. I. R.

No. 72-1361.

503 F.2d 359 (1974)

NOR-CAL ADJUSTERS, aka Nor-Cal Insurance Adjusters, formerly Hobson Adjusters, a corporation, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

September 5, 1974.

Attorney(s) appearing for the Case

Lee M. Galloway (argued), of Ingraham, Deming & Galloway, Sacramento, Cal., for appellant.

Wesley J. Filer, Atty. (argued), Tax Div., U. S. Dept. of Justice, Washington, D. C., for appellee.

Before BARNES and TRASK, Circuit Judges, and THOMPSON, District Judge.

OPINION

THOMPSON, District Judge:

This is an appeal from a decision of the United States Tax Court affirming the Commissioner's determination that bonuses paid to officer-shareholders of appellant Nor-Cal Adjusters (Nor-Cal) are not deductible business expenses within the meaning of § 162(a)(1) Internal Revenue Code of 1954. The Court has jurisdiction pursuant to § 7482 I.R.C. 1954.

Nor-Cal is a California corporation engaged in the business...

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