Court of Appeals for the Second Circuit December 22, 1949, 21464_1 (Whitman v. Commissioner of Internal Revenue)

FRANK, Circuit Judge.

The taxpayer, in 1943 and 1945, was not only the president and treasurer but also the holder of all but a few shares of the company’s stock.

1

In 1943, the company’s directors, in a resolution awarding her $20,000, stated that this sum represented compensation for her services over a five-year period beginning in 1938 during which she had been paid nothing.