TROUT-WARE, INC. v. COMMISSIONER

Docket No. 14910.

11 T.C. 505 (1948)

TROUT-WARE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 29, 1948.


Attorney(s) appearing for the Case

W. Dean Hopkins, Esq., for the petitioner.

Howard M. Kohn, Esq., for the respondent.


The Commissioner determined deficiencies in excess profits tax of $8,475.33 for 1943 and $2,841.85 for 1944. The only issue for decision is whether the petitioner was a personal service corporation during the taxable years within the meaning of section 725 of the Internal Revenue Code.

FINDINGS OF FACT.

The petitioner, a corporation, filed its returns for the taxable years with the collector of internal revenue for the eighteenth district of Ohio.

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