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HOWARD SOLE, INC. v. COMMISSIONER

Docket No. 34082.

12 T.C.M. 238 (1953)

Howard Sole, Inc. v. Commissioner.

United States Tax Court.

March 9, 1953.

Attorney(s) appearing for the Case

Robert J. Bannister, Esq., 1012 Bankers Trust Building, Des Moines, Ia., and James E. Cooney, Esq., for the petitioner. Everett E. Smith, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The Commissioner determined a deficiency of $10,998.61 in the income tax of the petitioner for 1946. The issue for decision is whether the Commissioner erred in holding that a reasonable allowance for 1946 as compensation for personal services rendered to the petitioner by Howard Sole, as its president was only $20,000 of the $48,943.70 claimed on the return.

Findings of Fact

The corporation...

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