J. H. Lane & Co. v. United States

The action in this case is the result of differences of opinion between the plaintiff and the Commissioner of Internal Revenue as to the sections of the internal-revenue laws of 1918 and 1919 under which the plaintiff’s income, war, and -excess-profits tax should be computed. No jurisdictional questions are involved, and the amount in dispute is $322,--079.16. The case is one of importance.

The revenue act of 1918, 40 Stat. 1059, provides in part as follows:

“ * * * The term ‘ personal-service corporation ’ means ..a corporation whose income is to be ascribed primarily to the activities of the…