CUYAHOGA ABSTRACT T. & T. CO. v. COM'R OF INTERNAL REVENUE

No. 4677.

29 F.2d 448 (1928)

CUYAHOGA ABSTRACT TITLE & TRUST CO. v. COMMISSIONER OF INTERNAL REVENUE.

Court of Appeals of District of Columbia.

Decided November 5, 1928.


Attorney(s) appearing for the Case

David J. Shorb, Ben Jenkins, and E. W. Wallick, all of Washington, D. C., for appellant.

LeRoy L. Hight, C. M. Charest, V. J. Heffernan, M. W. Willebrandt, Asst. Atty. Gen., and H. R. Gamble, all of Washington, D. C., for appellee.

Before MARTIN, Chief Justice, and ROBB and VAN ORSDEL, Associate Justices.


MARTIN, Chief Justice.

This is an appeal from a decision of the Board of Tax Appeals, reported in 7 B. T. A. 95, approving and affirming a determination of the Commissioner of Internal Revenue, finding the appellant liable for certain deficiencies in income and profits taxes for the years 1918, 1919, and 1920.

The controlling issue in the case is whether during these years the appellant was entitled to classification as a "personal service corporation," under...

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