# Peerless Engraving Co. v. Commissioner

> United States Board of Tax Appeals · January 26, 1926 · 3 B.T.A. 464

URL: https://www.frixlaw.com/law-library/cases/4494892

## Case

- **Full name:** APPEAL OF PEERLESS ENGRAVING CO.
- **Court:** United States Board of Tax Appeals
- **Decided:** January 26, 1926
- **Citations:** 3 B.T.A. 464; 1926 BTA LEXIS 2660
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Littleton
- **Judges:** James, Littleton, Smith, Trussell
- **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/4494892

## Opinion text

*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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4494892. Public record. Not legal advice.