Shaw-Walker Co. v. Commissioner
United States Tax Court
Petitioner filed a motion asking for a determination by the Court that the statement of the grounds on which petitioner relies to establish that none of its earnings and profits were permitted to accumulate beyond the reasonable needs of its business is sufficient under section 534, I.R.C. 1954, to place the burden of proof on respondent. Held, motion denied.
1Opinion of the Court
OPINION.
Tietjens, Judge:
On August 27, 1962, petitioner filed a motion for “Determination of Issues Under Section 534, Internal Revenue Code of 1954.” The gist of the motion is a request that the Court determine whether the statement of the grounds on which petitioner relies to establish that none of its earnings and profits were permitted to accumulate beyond the reasonable needs of its business (including the reasonably anticipated needs) is sufficient within the meaning of the pertinent sections of the Code to place upon respondent the burden of proving whether all or any part of…
2Cases cited2 opinions
- R. Gsell & Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Young Motor Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1960
3Cited by11 opinions
- Chatham Corp. v. CommissionerUnited States Tax Court · 1967
- Rhombar Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- The Shaw-Walker Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- Michael Di Peppino, Inc. v. CommissionerUnited States Tax Court · 1984
- Gustafson's Dairy v. CommissionerUnited States Tax Court · 1995
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