J. H. Taylor Construction Co. v. Commissioner

Board of Tax Appeals

J. H. Taylor Construction Co. v. Commissioner

13 B.T.A. 238

CourtUnited States Board of Tax Appeals

DecidedAugust 6, 1928

DocketDocket No. 11877

StatusPublished

Cited by1 cases

This text of 13 B.T.A. 238 (J. H. Taylor Construction Co. v. Commissioner) 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

J. H. Taylor Construction Co. v. Commissioner, 13 B.T.A. 238 (bta 1928).

Pincite

Opinion

[240]*240OPINION.

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.

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

[240]*240OPINION.

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.

Cite This Page — Counsel Stack

Bluebook (online)

13 B.T.A. 238, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-h-taylor-construction-co-v-commissioner-bta-1928.

Opinion

Related

Cite This Page — Counsel Stack