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DEXSIL CORP. v. C.I.R.

No. 95-4209.

147 F.3d 96 (1998)

DEXSIL CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided June 3, 1998.

Attorney(s) appearing for the Case

Mark R. Kravitz, New Haven, CT (Wiggin & Dana, New Haven CT, Daniel J. Klau, on brief), for Petitioner-Appellant.

Anthony T. Sheehan, Tax Div., Dept. of Justice, Washington, DC (Loretta C. Argrett, Asst. Atty. Gen.; Teresa E. McLaughlin, on brief), for Respondent-Appellee.

Before: VAN GRAAFEILAND, WALKER, and LEVAL, Circuit Judges.

JOHN M. WALKER, Jr., Circuit Judge:

Section 162(a) of the Internal Revenue Code, 26 U.S.C. § 162(a), provides that:

There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including — (1) a reasonable allowance for salaries or other compensation for personal services actually rendered;....

At issue in this case is whether the...

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