Sommerfeld Machine Company, Petitioner v. Commissioner of Internal Revenue, Respondent, 195 F.2d 736 (3d Cir. 1952)

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U.S. Court of Appeals for the Third Circuit - 195 F.2d 736 (3d Cir. 1952) Argued April 7, 1952
Decided April 17, 1952

Petition for Review of the Decision of the Tax Court of the United States.

R. J. Cleary, Pittsburgh, Pa., for petitioner.

Carlton Fox, Washington, D. C. (Ellis N. Slack, Acting Asst. Atty. Gen., on the brief), for respondent.

Before MARIS, GOODRICH and HASTIE, Circuit Judges.


The sole question in this case is whether the Tax Court erred in fixing allowances of compensation for the personal services rendered by the taxpayer's two principal officers in each of the years 1941 through 1944. 15 T.C. 453. We cannot say after reviewing the record that the Tax Court's findings as to these allowances were so unreasonable as to be clearly erroneous.

The decision of the Tax Court will be affirmed.