North American Ry. Const. Co. v. Commissioner

(after stating the facts as above). Section 200 of the Revenue Act of 1918 (Comp. St. § 6336%a) defines the term “personal service corporation” as “a corporation whose income is to be ascribed primarily to the activities of the principal owners or stockholders who are themselves regularly engaged in the active conduct of the affairs of the corporation and in which capital (whether invested or borrowed) is not a material income-producing factor.” That petitioner’s principal stockholders were, during the year 1918, “themselves regularly engaged in the active conduct of the affairs of the…