# Fuller Brush Co. v. Commissioner > United States Board of Tax Appeals · October 17, 1927 · 8 B.T.A. 855 URL: https://www.frixlaw.com/law-library/cases/4500497 ## Case - **Full name:** FULLER BRUSH CO., v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** October 17, 1927 - **Citations:** 8 B.T.A. 855; 1927 BTA LEXIS 2792 - **Precedential status:** Published - **Opinion:** Opinion of the court by Arundbll - **Judges:** Lansdon, Arundbll, Green - **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/4500497 ## Opinion text *856 OPINION. ARundbll : We have held that contingent reserves may not be deducted from income under the several revenue acts. Consolidated Asphalt Co., 1 B. T. A. 79; Uvalde Co., 1 B. T. A. 932; Pan-American Hide Co., 1 B. T. A. 1249; M. I. Stewart & Co., 2 B. T. A. 737; Crescent Cotton Co., 5 B. T. A. 850. Before an employee became entitled to a bonus he must have remained in petitioner’s employ for at least one year and must moreover have sold a certain amount of merchandise. On December 31, 1921, none of the employees for whom the reserve of $40,000 was established had been in petitioner’s employ for one year and no evidence was introduced as to the volume of their sales, or indeed what amount of merchandise they must sell to entitle them to a bonus. Petitioner’s liability being purely contingent, the deduction was properly disallowed. Judgment will be entered for the respondent. Considered by Lansdon and Green. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4500497. Public record. Not legal advice.