Petitioner challenges respondent's determination of deficiencies in excess profits tax for the calendar years 1942 and 1943 in the respective amounts of $39,197.05 and $47,300.76.
The sole issue is whether petitioner is exempt from excess profits tax as a personal service corporation, as defined in section 725 (a) of the Internal Revenue Code. The issue is further narrowed by the parties to a consideration of whether capital was a "material income-producing factor...
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