FARMERS NATIONAL CO. v. COMMISSIONER

Docket No. 18383.

13 T.C. 505 (1949)

FARMERS NATIONAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 30, 1949.


Attorney(s) appearing for the Case

Paul L. Martin, Esq., for the petitioner.

George E. Gibson, Esq., for the respondent.


This proceeding involves excess profits tax deficiencies of $31,988.90 and $6,246.24 for 1943 and 1944, respectively. Some of the issues raised in the pleadings were waived by counsel for the petitioner at the hearing. The only issue remaining for our determination is whether the petitioner, during the taxable years 1943 and 1944, was a personal service corporation within the meaning of section 725, Internal Revenue Code. The facts have been stipulated in part and are found...

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