Appeal of Peerless Engraving Co.

Board of Tax Appeals

Appeal of Peerless Engraving Co.

3 B.T.A. 464

CourtUnited States Board of Tax Appeals

DecidedJanuary 26, 1926

DocketDocket No. 3626

StatusPublished

Cited by1 cases

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

Pincite

Opinion

[467]*467OPINION.

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.

Free access — add to your briefcase to read the full text and ask questions with AI

[467]*467OPINION.

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.

Cite This Page — Counsel Stack

Bluebook (online)

3 B.T.A. 464, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-peerless-engraving-co-bta-1926.

Opinion

Related

Cite This Page — Counsel Stack