G. Angelo Co. v. Commissioner

*463OPINION.

Love.'

In the first issue petitioner, the G. Angelo Co., claims to be a personal service corporation and, therefore, it is exempt from taxation as a corporation as provided in section 200 and section 218 (e) of the Revenue Act of 1918. The provisions of section 200 material to the issue are as follows:

The term “ personal service corporation ” means a corporation -whose income is to bo ascribed primarily to the activities of tbe principal owners or stockholders who are themselves regularly engaged In the active conduct of the affairs of the corporation and in which capital (whether…