General Management Corp. v. COM'R OF INT. REVENUE

LINDLEY, District Judge.

Petitioner questions a decision of the Tax Court declaring it a personal holding company in the taxable year 1938, for the reason that more than 80 per cent of its gross income for that year constituted “personal service corporate income” within the meaning of Section 402 of the Revenue Act of 1938, 26 U.S.C.A. Int.Rev. Code, § 501. The propriety of the decision depends wholly upon whether a contract with United Printers and Publishers, Inc., hereafter referred to as United, from which it derived $24,000, was a “personal service contract” which “designated” the person…