United States Board of Tax Appeals February 28, 1925, Docket No. 1036 (Appeal of Joseph Emsheimer Insurance Agency)

*652OPINION.

Smith :

What constitutes a “ personal service corporation ” within the meaning of the Kevenue Act of 1918 is set forth in section 200 of that act. Two of the requisites of such a corporation are that its income shall be (1) “ascribed primarily to the activities of the principal owners or stockholders,” and (2) that such principal owners or stockholders shall be “ regularly engaged in