Gus Sun Booking Exchange Co. v. Commissioner

*1200OPINION.

Teakmell:

The principal question involved is whether the petitioner meets the tests required by section 200 of the Revenue Act of 1918, which is as follows:

The term “ personal service corporation ” means 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; but does not include any foreign corporation, nor any corporation 59 per centum or more…