W. J. Perry Corp. v. Commissioner

Board of Tax Appeals

W. J. Perry Corp. v. Commissioner

1 B.T.A. 788, 1925 BTA LEXIS 2793

CourtUnited States Board of Tax Appeals

DecidedMarch 17, 1925

DocketDocket No. 1360.

StatusPublished

This text of 1 B.T.A. 788 (W. J. Perry Corp. 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

W. J. Perry Corp. v. Commissioner, 1 B.T.A. 788, 1925 BTA LEXIS 2793 (bta 1925).

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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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[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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Bluebook (online)

1 B.T.A. 788, 1925 BTA LEXIS 2793, Counsel Stack Legal Research, https://law.counselstack.com/opinion/w-j-perry-corp-v-commissioner-bta-1925.

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