ROSEN REICHERT BROKERAGE CO. v. UNITED STATES

No. M — 117.

3 F.Supp. 646 (1933)

ROSEN REICHERT BROKERAGE CO. v. UNITED STATES.

Court of Claims.

June 5, 1933.


Attorney(s) appearing for the Case

John Enrietto, of Washington, D. C. (Chester A. Bennett, of Washington, D. C., Chase Morsey, of St. Louis, Mo., and Charles D. Hamel, of Washington, D. C., on the brief), for plaintiff.

George H. Foster, of Washington, D. C., and Charles B. Rugg, Asst. Atty. Gen. (Kelly Kash, of Washington, D. C., on the brief), for the United States.

Before LITTLETON, WHALEY, WILLIAMS, and GREEN, Judges.


LITTLETON, Judge.

The question in this case is whether plaintiff was a personal-service corporation during either or both of the years 1918 and 1919 within the meaning of section 200 of the Revenue Act of 1918 (40 Stat. 1058) and the answer to this question turns upon whether capital was a material income-producing factor. No question is made by the defendant as to the other requirements of the statute.

The question whether a corporation is entitled to personal...

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