Meinrath Brokerage Co. v. COMMISSIONER OF I. REVENUE

WOODROUGH, District Judge.

This is an appeal from the orders of the United States Board of Tax Appeals finding deficiencies in income taxes against appellant for the years 1918 to 1921, inclusive, in the amount of $100,006.95. The appellant had filed its income tax returns for the years in question as a personal service corporation under section 200 of the Revenue Acts of 1918 and 1921 (40 Stat. 1058, 42 Stat. 227); but the Commissioner of Internal Revenue, upon audit of the corporation, refused to classify the appellant as such personal service corporation. The appellant petitioned the Board…