Commissioner v. Renyx

SWAN, Circuit Judge.

Harmon & Co. was incorporated in 1917 under the laws of Delaware for the purpose of selling stock of another corporation upon a commission basis. Eor the year 1919 it filed an informational return as a personal service corporation, showing the payment of salaries to its three officers in an aggregate amount of more than $228,000. Each of its three officers owned one-third of its capital stock. The Commissioner denied the corporation personal service classification, reduced the deduction for officers’ salaries to $84,000, and determined a deficiency in income and profits…