St. Paul Abstract Co. v. Commissioner

STONE, Circuit Judge.

This is a petition to review a decision of the Board of Tax *226Appeals, -which sustained the income tax against petitioner. The basis of petitioner’s objection to the levy of the tax is that it is not subject thereto, because it is a “personal service corporation,” within the meaning of section 200 of the Revenue Act of 1918 (40 Stat. 1057, 1059).

Two questions are presented here — the first, a matter of procedure; the second, the application of section 200 of the Revenue Act of 1918.

I. The Board of Tax Appeals made extended findings of fact concerning the business of…