HUBBARD-RAGSDALE CO. v. DEAN

No. 3562.

15 F.2d 410 (1926)

HUBBARD-RAGSDALE CO. v. DEAN, Internal Revenue Collector.

District Court, S. D., Ohio, W. D.

May 22, 1926.


Attorney(s) appearing for the Case

Hunt, Bennett & Utter, of Cincinnati, Ohio, for plaintiff.

Haveth E. Mau, U. S. Atty., and Simon Ross, Asst. U. S. Atty., both of Cincinnati, Ohio, and T. H. Lewis, Jr., Sp. Atty. Bureau of Internal Revenue, of Washington, D. C., for defendant.


HICKENLOOPER, District Judge.

The only question raised in this action is whether the plaintiff corporation is entitled to classification as a personal service corporation under the Internal Revenue Act of 1918 (40 Stat. 1057). Section 200 of this act (Comp. St. § 6336 1/8a) provides:

"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...

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