Long v. Commissioner

MOORMAN, Circuit Judge.

This case involves income and profit taxes of the Star Warehouse Company, a dissolved corporation, which were asserted against the petitioner, a former stockholder and a distributee of corporate assets. The questions presented on the record are: (1) Whether section 289 of the Revenue Act of 192-6 (26 USCA § 1969), under which the liability was asserted, is constitutional; and (2) whether for the taxable period, November 7,1919, to October 39,1929, the corporation was entitled to classification as a personal service corporation within the meaning of section 299 of the…