*189OPINION.
Muedocii :If any corporation operating a hotel fulfills the requirements of a personal service corporation, as defined in section 200 of the Revenue Act of 1918, it is most exceptional, but certainly the present petitioner fails to fulfill those requirements. Appeal of Newam Theatre Corporation, 1 B. T. A. 887; Mountain View Sanitarium Co., 2 B. T. A. 417; Cotton Hotel Co. v. Bass, 7 Fed. (2d) 900.
Judgment will he entered for the Commissioner.