Respondent determined deficiencies in the income tax of S.O. Claggett, Inc., for the calendar years 1958, 1959, and 1960 in the respective amounts of $5,894.78, $15,449.32, and $7,663.66.
The issue for decision is whether during the taxable years 1958 through 1961 petitioner's income was derived from a personal service contract and therefore constituted personal holding company income within the...
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