Metropolitan Business College v. Blair

ALSCHULER, Circuit Judge.

Petitioner, a corporation, attacks an order of the Board of Tax Appeals fixing petitioner’s unpaid tax for 1918 at $8,051.06, and for 1919 at $5,478.23, which accords with the finding of the Commissioner of Internal Revenue, from whose determination petitioner had prosecuted an appeal to the board.

The broad question is whether petitioner is a “personal service corporation,” within the meaning of section 200 of the Revenue Act of 1918 '(Comp. St. § 6336%a), which reads:

“That when used in this title— * * * The term- ‘personal service corporation’ means a corporation…