Technalysis Corp. v. Commissioner
United States Tax Court
R determined that P, a publicly held corporation, unreasonably accumulated its earnings and profits and, therefore, was subject to the accumulated earnings tax. P argued that the accumulated earnings tax does not apply to publicly held corporations which do not have a shareholder, or a small group of shareholders, who control more than 50 percent of the stock.
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R determined that P, a publicly held corporation, unreasonably accumulated its earnings and profits and, therefore, was subject to the accumulated earnings tax. P argued that the accumulated earnings tax does not apply to publicly held corporations which do not have a shareholder, or a small group of shareholders, who control more than 50 percent of the stock. P further argued that, if the tax can apply, its accumulation was not unreasonable and it lacked the proscribed purpose. Held, the accumulated earnings tax can apply to a publicly held corporation regardless of the concentration of…
1Opinion of the Court
Technalysis Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Technalysis Corp. v. Commissioner
Docket No. 3238-91
United States Tax Court
101 T.C. 397; 1993 U.S. Tax Ct. LEXIS 68; 101 T.C. No. 27;
November 4, 1993, Filed
Decision will be entered for petitioner.
R determined that P, a publicly held corporation, unreasonably accumulated its earnings and profits and, therefore, was subject to the accumulated earnings tax. P argued that the accumulated earnings tax does not apply to publicly held corporations which do not have a shareholder, or a small group of shareholders, who…
2Cases cited17 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. Donruss Co.Supreme Court of the United States · 1969
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
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