Alexander & Garrett v. United States

BARRETT, District Judge.

By appropriate stipulation between counsel for the parties, this case is for determination as to the facts as well as the law by the court alone.

■ There are only two questions for answer in the ease: (1) Was the plaintiff taxable for the year 1917 under section 209 of the Revenue Act of 1917 or under section 201 (Comp. St. §§ 6336%j, 6336%b) ? and (2) Was the plaintiff in the years 1918, 1919, 1920, and 1921 taxable as a personal service corporation ?

The plaintiff was a corporation during all the years in. question, with a capital stock of $75,000, styled during 1917…