Farnham Mfg. Co. v. Commissioner
United States Tax Court
During the taxable years, petitioner was engaged in designing and engineering special machinery to be used in manufacturing airplane wings. Its capital stock was owned by four stockholders, all of whom were regularly engaged in the active conduct of the business. Capital was not an income-producing factor. Held, petitioner is entitled to personal service classification under the provisions of section 725, I. R. C.
1Opinion of the Court
Farnham Manufacturing Company, Successor by Merger to Paragon Research, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Farnham Mfg. Co. v. Commissioner
Docket No. 16299
United States Tax Court
13 T.C. 511; 1949 U.S. Tax Ct. LEXIS 76;
September 30, 1949, Promulgated
Decision will be entered under Rule 50.
During the taxable years, petitioner was engaged in designing and engineering special machinery to be used in manufacturing airplane wings. Its capital stock was owned by four stockholders, all of whom were regularly engaged in the active conduct of the business. Capital was not…
2Cases cited2 opinions
- Whittelsey, Inc. v. CommissionerUnited States Tax Court · 1947
- Farnham Mfg. Co. v. CommissionerUnited States Tax Court · 1949