J. H. Taylor Constr. Co. v. Commissioner

Board of Tax Appeals

J. H. Taylor Constr. Co. v. Commissioner

13 B.T.A. 238, 1928 BTA LEXIS 3291

United States Board of Tax Appeals·Decided August 6, 1928·No. Docket No. 11877.·Published·Cited by 1 cases

Opinion

[240] OPINION.

Smith:

There can be no question in this case that the income of the petitioner was ascribable primarily to the activities of the principal stockholders who were themselves regularly engaged in the active conduct of the affairs of the corporation. Capital was not a material income-producing factor. The petitioner meets all the requirements of a personal service corporation as defined in section 200 of the Revenue Act of 1918.

Judgment of no deficiency will be entered for the fetitioner.

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[240] OPINION.

Smith:

There can be no question in this case that the income of the petitioner was ascribable primarily to the activities of the principal stockholders who were themselves regularly engaged in the active conduct of the affairs of the corporation. Capital was not a material income-producing factor. The petitioner meets all the requirements of a personal service corporation as defined in section 200 of the Revenue Act of 1918.

Judgment of no deficiency will be entered for the fetitioner.

J. H. Taylor Constr. Co. v. Commissioner, 13 B.T.A. 238, 1928 BTA LEXIS 3291 (bta 1928).

Pincite

13 B.T.A. 238 (J. H. Taylor Constr. Co. v. Commissioner) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

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