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" ... (3) In any event the allowance for the compensation paid may not exceed what is reasonable under all the circumstances. It is, in general, just to assume that reasonable and true compensation is only such amount as would ordinarily be paid for like... "
Code of Federal Regulations: Containing a Codification of Documents of ... - Page 348
1970
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Cases Decided in the United States Court of Claims ... with ..., Volume 118

United States. Court of Claims, Audrey Bernhardt - 1951 - 840 pages
...Regulations. Section 19.23 (a) -6 of Regulations 103 says in part : 941207—51 17 Opinion of the Court The circumstances to be taken into consideration are...existing at the date when the contract is questioned. At the time this salary arrangement was agreed upon it appeared to be a reasonable one. As it turned...
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Taxation of Corporations and Personal Income in New York

Henry Montefiore Powell - 1919 - 708 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. See article 32. (Art. 105 — Reg. 45, Rev.) Commissions paid to salesmen. — Commissions paid to...
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Prentice-Hall Tax Service for 1919 (Classic Reprint)

Prentice-Hall Inc, Prentice-Hall, inc - 1919 - 640 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. See article 32. 1[ 577. Art. 106. Treatment of excessive compensation. — As to the treatment of amounts...
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Comptroller's Regulations Relating to the Income Tax Issued Pursuant to ...

1920 - 188 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. (Article 28.) The father is legally* entitled to the services of his unemancipated minor children and...
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Regulations 45 Relating to the Income Tax and War Profits and Excess Profits ...

United States. Bureau of Internal Revenue - 1920 - 346 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. See article 32. ART. 106. Treatment of excessive compensation. — As to the treatment of amounts ostensibly...
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Federal Income Tax, War-profits and Excess-profits Taxes: Including Stamp ...

George Edwin Holmes - 1920 - 1186 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...not those existing at the date when the contract is questioned.31 SALARIES CONSTITUTING A DISTRIBUTION OP DIVIDENDS. Any amount paid in the form of a salary,...
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Regulations 45 (1920 Ed.) Relating to the Income Tax and War Profits and ...

United States. Internal Revenue Service - 1921 - 348 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. See article 32. ART. 106. Treatment of excessive compensation. — As to the treatment of amounts ostensibly...
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Federal Income Tax Problems --1922

Emerson Emanuel Rossmoore - 1922 - 592 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. . . . The circumstances to be...existing at the date when the contract is questioned." PROBLEM 93 Illustrating Deductions not Allowed Corporation—Salaries paid in Lieu of Dividends FACTS...
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Regulations 65 Relating to the Income Tax Under the Revenue Act of 1924

United States. Internal Revenue Service - 1924 - 396 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...existing at the date when the contract is questioned. See article 32. in the hands of the recipient. If such payments constitute, in part, payment for property,...
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Cases on Federal Taxation, Volume 1

Joseph Henry Beale, Roswell Foster Magill - 1926 - 744 pages
...compensation is only such amount as would ordinarily be paid for like services by like enterprises in like circumstances. The circumstances to be taken...when the contract for services was made, not those existingat thedate when the contract is questioned. (See article 3 2.) ART. 107. Treatment of excessive...
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