Farmers Nat'l Co. v. Commissioner
United States Tax Court
Corporation engaged in the business of managing farms for absentee owners, employing trained agriculturists to do the actual work of surveying and platting the farm, planting the crops, and supervising the operation of each farm, under the direction of its three principal officers, who owned, individually or through their wives, more than 70 per cent of the corporation's stock, and who devoted full time to the business, held, not a personal service corporation within the…
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Corporation engaged in the business of managing farms for absentee owners, employing trained agriculturists to do the actual work of surveying and platting the farm, planting the crops, and supervising the operation of each farm, under the direction of its three principal officers, who owned, individually or through their wives, more than 70 per cent of the corporation's stock, and who devoted full time to the business, held, not a personal service corporation within the meaning of section 725, I. R. C.
1Opinion of the Court
OPINION.
LeMire, Judge-.
The respondent determined in his notice of deficiency that:
* * * the income realized for the years here in issue may not be ascribed primarily to the activities of your shareholders who are regularly engaged in the active conduct of your affairs, and that capital is a material income producing factor. Tour contention that the corporation is a personal service corporation is denied.
The respondent states in his brief that he does not contend in this proceeding that capital was an income-producing factor, but does contend that the income may not be ascribed to the…
2Cases cited1 opinion
- Whittelsey, Inc. v. CommissionerUnited States Tax Court · 1947
3Cited by1 opinion
- Farmers Nat'l Co. v. CommissionerUnited States Tax Court · 1949