EXACTO SPRING CORP. v. C.I.R.

No. 99-1011.

196 F.3d 833 (1999)

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

United States Court of Appeals, Seventh Circuit.

Decided November 16, 1999.


Attorney(s) appearing for the Case

Robert E. Dallman (argued), Vincent J. Beres, Reinhart, Boerner, VanDeuren, Norris & Rieselbach, Milwaukee, WI, for Petitioner-Appellant.

Tamara W. Ashford (argued), William S. Estabrook, Department of Justice, Tax Division, Appellate Section, Washington, DC, William F. Hammack, Internal Revenue Service, Office of Regional Counsel (Midstates), Dallas, TX, for Respondent-Appellee.

Before POSNER, Chief Judge, and BAUER and RIPPLE, Circuit Judges.


POSNER, Chief Judge.

This appeal from a judgment by the Tax Court, 75 T.C.M. (CCH) 2522 (June 24, 1998), requires us to interpret and apply 26 U.S.C. § 162(a)(1), which allows a business to deduct from its income its "ordinary and necessary" business expenses, including a "reasonable allowance for salaries or other compensation for personal services actually rendered." In 1993 and 1994, Exacto Spring Corporation, a closely held...

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