BOURQUIN, District Judge.
Plaintiff, in 1923, under protest, paying excess profits taxes for 1917 and 1918, sues to recover them.
Practically the only issue is whether plaintiff then was "a personal service corporation having a nominal capital," and so exempt.
From the evidence it appears that in 1897 plaintiff was incorporated with $30,000 capital stock, as full paid then exchanged for the good will of the predecessor in the business to which it succeeded...
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