United States Board of Tax Appeals, 1926

Appeal of Peerless Engraving Co.

Appeal of Peerless Engraving Co.
United States Board of Tax Appeals · Decided January 26, 1926 · James, Littleton, Smith, Trussell
3 B.T.A. 464
Appeal of Peerless Engraving Co.

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Opinion of the Court

*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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