Appeal of W. J. Perry Corp.

*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.