Appeal of Peerless Engraving Co.

Board of Tax Appeals

Appeal of Peerless Engraving Co.

3 B.T.A. 464

United States Board of Tax Appeals·Decided January 26, 1926·No. Docket No. 3626·Published·Cited by 1 cases

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.

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[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.

Appeal of Peerless Engraving Co., 3 B.T.A. 464 (bta 1926).

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Opinion

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