# Reynard Corp. v. Commissioner > United States Board of Tax Appeals · April 20, 1934 · 30 B.T.A. 451 URL: https://www.frixlaw.com/law-library/cases/4495180 ## Case - **Full name:** REYNARD CORPORATION, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** April 20, 1934 - **Citations:** 30 B.T.A. 451; 1934 BTA LEXIS 1325 - **Precedential status:** Published - **Opinion:** Dissent by Leech - **Judges:** Leech, Maequette - **Cited by:** 20 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4495180 ## Opinion text Leech, dissenting: The majority opinion, although it approves the charging of the petitioner, Fox, with additional compensation for the rental value of the corporation’s residence which he used during the taxable years, reverses the action of the respondent in including this identical rental value in the corporation’s income for the same *455 years. I think the decision upon this latter action inconsistent with the former and erroneous. This amount, recognized as compensation to Fox from the corporation, must be treated as having been constructively paid to the corporation as rental, and therefore taxable income, to it, before it can be held to have been paid by the corporation to Fox. Cf. Burnet v. Wells, 289 U.S. 670 . Sea well agrees with this dissent. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4495180. Public record. Not legal advice.