Facts: The National Coal Co. (NCC) was created by a special law and was enacted by virtue of Act 2705 in order to develop a coal industry. It was engaged in coal mining on reserved lands belonging to the government. The National Coal Co. (NCC) filed a case against the CIR for the recovery of sum of money it paid on protest as specific tax on 24,089 tons of coals claiming exemption to tax pursuant to Sec. 14 and 15 of Act 2719. Issue: Whether or not NCC is a private corporation? Held: Plaintiff is a private corporation. The mere fact that the government is a majority stockholder of the corporation does not make the corporation.