Ivan Allen Co. v. United States

Sections 531-537, inclusive, of the Internal Revenue Code of 1954, as amended, 26 U. S. C. §§ 531-537, con*618stitute Part I of subchapter G of the Income Tax Subtitle. These sections subject most corporations to an “accumulated earnings tax.” Section 5311 imposes the tax upon the “accumulated taxable income” of every corporation that, as § 532 (a) states,2 is “formed or availed of for the purpose of avoiding the income tax with respect to its shareholders ... by permitting earnings and profits to accumulate instead of being divided or distributed.” And § 533 (a) 3 provides that “the fact that…