# King-Parker, Inc. v. Commissioner

> United States Board of Tax Appeals · April 18, 1927 · 6 B.T.A. 884

URL: https://www.frixlaw.com/law-library/cases/4499904

## Case

- **Full name:** KING-PARKER, INC., <emphasis typestyle="it">v.</emphasis> COMMISSIONER OF INTERNAL REVENUE
- **Court:** United States Board of Tax Appeals
- **Decided:** April 18, 1927
- **Citations:** 6 B.T.A. 884; 1927 BTA LEXIS 3382
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Milliken
- **Judges:** Milliken
- **Cited by:** 0 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/4499904

## Opinion text

*886 OPINION.
Milliken
The respondent concedes the reasonableness of the total salary payments made to King and Isaacs in the year 1920. The question presented is whether the compensation to the two officers and directors was properly determined and constituted a deductible expense for the year. From the evidence adduced we have found as a fact that the payments were made for personal services actually rendered in the year 1920, as distinguished from repayments for loans or money advanced or dividends declared or paid. Petitioner was a close corporation and the additional salaries claimed as a deduction were agreed upon and authorized pursuant to the informal agreement entered into and meetings held in the year 1920. See Appeal of Reub Isaacs & Co., 1 B. T. A. 45.
Judgment will be entered on 15 days’ notice, in accordance with Bule 50.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4499904. Public record. Not legal advice.
