Opinion

Peerless Engraving Co. v. Commissioner

  • 3 B.T.A. 464
  • 1926 BTA LEXIS 2660
Court
United States Board of Tax Appeals
Filed
Jan 26, 1926
Status
Published
Author
Littleton
On the bench
James, Littleton, Smith, Trussell
Cited by
0 cases

The opinion

*467 OPINION.

Littleton:

From the evidence before ns, we are of the opinion that the taxpayer is not entitled to classification as a personal service corporation. It is true that the principal and only stockholder was regularly engaged in the active conduct of the business, but it can not be said that the taxpayer’s income was due primarily to his activities. Both capital and the activities of other employees were material income-producing factors.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.