G. Angelo & Co. v. Commissioner

In my view the facts found by the Board negative their conclusion that the petitioner is not entitled to classification as a personal service corporation. The three stockholders worked from 14 to 20 hours a day at the corporation’s business, without salaries. Their activities consisted in obtaining orders, mostly from their Italian compatriots, for bananas, at prices fixed by the fruit company. The fruit was shipped by the fruit company, at its own expense, direct to these purchasers. The petitioner carried no stock of bananas. The fruit company invoiced the bananas thus sold to the…