# Spark Hotel Co. v. Commissioner

> United States Board of Tax Appeals · October 26, 1926 · 5 B.T.A. 186

URL: https://www.frixlaw.com/law-library/cases/4499329

## Case

- **Full name:** SPARK HOTEL CO., <emphasis typestyle="it">v.</emphasis> COMMISSIONER OF INTERNAL REVENUE
- **Court:** United States Board of Tax Appeals
- **Decided:** October 26, 1926
- **Citations:** 5 B.T.A. 186; 1926 BTA LEXIS 2938
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Muedocii
- **Judges:** Muedocii
- **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/4499329

## Opinion text

*189 OPINION.
Muedocii :
If any corporation operating a hotel fulfills the requirements of a personal service corporation, as defined in section 200 of the Revenue Act of 1918, it is most exceptional, but certainly the present petitioner fails to fulfill those requirements. Appeal of Newam Theatre Corporation, 1 B. T. A. 887; Mountain View Sanitarium Co., 2 B. T. A. 417; Cotton Hotel Co. v. Bass, 7 Fed. (2d) 900.
Judgment will he entered for the Commissioner.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4499329. Public record. Not legal advice.
