Cotton Hotel Co. v. Bass

WEST, District Judge.

The defendant, collector of internal revenue, is sued for the recovery of certain moneys paid by plaintiff company as income and profits taxes, which it claims were erroneously and illegally assessed against it for the years 1920 and 1921. The action results from a disallowance of plaintiff’s claim for exemption under sections 218 and 231 (14) as a personal service corporation, as defined in section 200 of the Revenue Acts of 1918 and 1921 (Comp. St. Ann. Supp. 1919, Comp. St. Ann. Supp. 1923, §§ 6336%a, 6336%i, 6336y8o).

The plaintiff, Cotton Hotel Company, was organized…