Appeal of John Dais Co.

Board of Tax Appeals

Appeal of John Dais Co.

2 B.T.A. 1167

CourtUnited States Board of Tax Appeals

DecidedNovember 4, 1925

DocketDocket No. 1913

StatusPublished

Cited by1 cases

This text of 2 B.T.A. 1167 (Appeal of John Dais Co.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of John Dais Co., 2 B.T.A. 1167 (bta 1925).

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Opinion

[1168]*1168OPINION.

Marquette:

Regardless of the credit period granted purchasers from the taxpayer, remittances to consignors were made immediately upon the disposal of a consignment. That this required the use in the taxpayer’s business of a large amount of cash capital is evident from the fact that credit extended during 1918 totaled approximately $125,000. It also appears that this credit business represented a very substantial portion of the taxpayer’s entire sales. The Board is of opinion that this use of capital was a material income-producing factor in the taxpayer’s business and therefore that the Commissioner’s denial of personal-service classification is proper.

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[1168]*1168OPINION.

Marquette:

Regardless of the credit period granted purchasers from the taxpayer, remittances to consignors were made immediately upon the disposal of a consignment. That this required the use in the taxpayer’s business of a large amount of cash capital is evident from the fact that credit extended during 1918 totaled approximately $125,000. It also appears that this credit business represented a very substantial portion of the taxpayer’s entire sales. The Board is of opinion that this use of capital was a material income-producing factor in the taxpayer’s business and therefore that the Commissioner’s denial of personal-service classification is proper.

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2 B.T.A. 1167, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-john-dais-co-bta-1925.

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