New Orleans Shipwright Co. v. Commissioner of Internal Revenue

EOSTER, Circuit Judge.

The petitioner filed returns for income and profits taxes for the years 1918, 1920, and 1921 as a personal service corporation. The Commissioner of Internal Revenue held it was not such a corporation, and determined deficiencies amounting to $59,886.10 for these years. Appeals, were taken to the Board of Tax Appeals, and the cases were consolidated and referred to a division consisting of one member. Evidence was taken before the division, and he made findings of facts which are not disputed. Those material to a decision are, in substance, as follows:

Petitioner is a…