John Dais Co. v. Commissioner

Board of Tax Appeals

John Dais Co. v. Commissioner

2 B.T.A. 1167, 1925 BTA LEXIS 2139

CourtUnited States Board of Tax Appeals

DecidedNovember 4, 1925

DocketDocket No. 1913.

StatusPublished

This text of 2 B.T.A. 1167 (John Dais 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

John Dais Co. v. Commissioner, 2 B.T.A. 1167, 1925 BTA LEXIS 2139 (bta 1925).

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Opinion

[1168]*1168OPINION.

Marquette:

Regardless of the credit period granted purchasers from the taxpayer, remittances to consignors were made immediately upon the disposal of a consignment. That this required the use in the taxpayer’s business of a large amount of cash capital is evident from the fact that credit extended during 1918 totaled approximately $125,000. It also appears that this credit business represented a very substantial portion of the taxpayer’s entire sales. The Board is of opinion that this use of capital was a material income-producing factor in the taxpayer’s business and therefore that the Commissioner’s denial of personal-service classification is proper.

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[1168]*1168OPINION.

Marquette:

Regardless of the credit period granted purchasers from the taxpayer, remittances to consignors were made immediately upon the disposal of a consignment. That this required the use in the taxpayer’s business of a large amount of cash capital is evident from the fact that credit extended during 1918 totaled approximately $125,000. It also appears that this credit business represented a very substantial portion of the taxpayer’s entire sales. The Board is of opinion that this use of capital was a material income-producing factor in the taxpayer’s business and therefore that the Commissioner’s denial of personal-service classification is proper.

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Bluebook (online)

2 B.T.A. 1167, 1925 BTA LEXIS 2139, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-dais-co-v-commissioner-bta-1925.

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