United States Board of Tax Appeals, 1925

Appeal of John Dais Co.

Appeal of John Dais Co.
United States Board of Tax Appeals · Decided November 4, 1925 · Maequette, Marquette, Morris
2 B.T.A. 1167
Appeal of John Dais Co.

Cases that cite this one

1 later published case cites this decision.

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Opinion of the Court

*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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.