United States Board of Tax Appeals January 12, 1928, Docket No. 10786. (Gus Sun Booking Exchange Co. v. Commissioner)

lead-opinion

*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