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COTTON HOTEL CO. v. BASS

No. 1074.

7 F.2d 900 (1925)

COTTON HOTEL CO. v. BASS, Collector of Internal Revenue.

District Court, W. D. Texas. Austin Division.

July 6, 1925.

Attorney(s) appearing for the Case

McDonald & Wayman, of Galveston, Tex., for plaintiff.

John D. Hartman, U. S. Dist. Atty., of San Antonio, Tex., and Floyd Toomey, Sp. Atty. Int. Rev., of Washington, D. C., for the United States.

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

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