Peerless Engraving Co. v. Commissioner

Board of Tax Appeals

Peerless Engraving Co. v. Commissioner

3 B.T.A. 464, 1926 BTA LEXIS 2660

CourtUnited States Board of Tax Appeals

DecidedJanuary 26, 1926

DocketDocket No. 3626.

StatusPublished

This text of 3 B.T.A. 464 (Peerless Engraving 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

Peerless Engraving Co. v. Commissioner, 3 B.T.A. 464, 1926 BTA LEXIS 2660 (bta 1926).

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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.

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[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.

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Bluebook (online)

3 B.T.A. 464, 1926 BTA LEXIS 2660, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peerless-engraving-co-v-commissioner-bta-1926.

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