Legal Opinion

Farmers Nat'l Co. v. Commissioner

United States Tax Court

Decided September 30, 1949No. Docket No. 18383Published

Corporation engaged in the business of managing farms for absentee owners, employing trained agriculturists to do the actual work of surveying and platting the farm, planting the crops, and supervising the operation of each farm, under the direction of its three principal officers, who owned, individually or through their wives, more than 70 per cent of the corporation's stock, and who devoted full time to the business, held, not a personal service corporation within the…

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Corporation engaged in the business of managing farms for absentee owners, employing trained agriculturists to do the actual work of surveying and platting the farm, planting the crops, and supervising the operation of each farm, under the direction of its three principal officers, who owned, individually or through their wives, more than 70 per cent of the corporation's stock, and who devoted full time to the business, held, not a personal service corporation within the meaning of section 725, I. R. C.

1Opinion of the Court

Farmers National Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Farmers Nat'l Co. v. Commissioner

Docket No. 18383

United States Tax Court

13 T.C. 505; 1949 U.S. Tax Ct. LEXIS 75;

September 30, 1949, Promulgated

Decision will be entered for the respondent.

Corporation engaged in the business of managing farms for absentee owners, employing trained agriculturists to do the actual work of surveying and platting the farm, planting the crops, and supervising the operation of each farm, under the direction of its three principal officers, who owned, individually or through their…

2Cases cited2 opinions

  1. Whittelsey, Inc. v. CommissionerUnited States Tax Court · 1947
  2. Farmers Nat'l Co. v. CommissionerUnited States Tax Court · 1949

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