FARNHAM MANUFACTURING CO. v. COMMISSIONER

Docket No. 16299.

13 T.C. 511 (1949)

FARNHAM MANUFACTURING COMPANY, SUCCESSOR BY MERGER TO PARAGON RESEARCH, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 30, 1949.


Attorney(s) appearing for the Case

J. Eugene McMahon, Esq., and Stanley H. Montfort, Esq., for the petitioner.

William A. Schmitt, Esq., for the respondent.


The respondent determined deficiencies of $47,797.11 and $21,151.75 in the petitioner's excess profits tax liability for the fiscal years ended June 30, 1943 and 1944, respectively. He also determined an overassessment in income tax for those respective years in the amounts of $23,165.55 and $7,143.35.

The sole issue is whether or not the petitioner is entitled to be classified as a personal service corporation under the provisions of section 725 of the Internal Revenue...

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