Appeal of W. J. Perry Corp.
This text of 1 B.T.A. 788 (Appeal of W. J. Perry Corp.) 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.
Opinion
[790]*790DECISION.
The facts in this appeal are substantially the same as those in the Appeal of Joseph Emsheimer Insurance Agency, 1 B. T. A. 649. Approximately one-half of the net income of the taxpayer is ascribable primarily to the activities of subagents. Such income is not ascribable primarily to the activities of the principal stockholders of the taxpayer.
The determination of the Commissioner is approved.
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