Farmers National Co. v. Commissioner

OPINION.

LeMire, Judge-.

The respondent determined in his notice of deficiency that:

* * * the income realized for the years here in issue may not be ascribed primarily to the activities of your shareholders who are regularly engaged in the active conduct of your affairs, and that capital is a material income producing factor. Tour contention that the corporation is a personal service corporation is denied.

The respondent states in his brief that he does not contend in this proceeding that capital was an income-producing factor, but does contend that the income may not be ascribed to the…